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Statement Regarding the Budget Implementation Act Amendments

Statement Regarding the Budget Implementation Act Amendments


Imagine Canada was pleased to see two amendments to the Budget Implementation Act (BIA) pass on May 30th at the House of Commons Standing Committee of Finance. The amendments remove prescriptive language in the BIA in favour of improved language that will make it more possible for charities to equitably partner with non-qualified donees (NQD). The nonprofit and charitable sector appreciated the care and urgent attention the government gave these amendments over the last few weeks. The sector worked closely with Senator Ratna Omidvar and a coalition of like-minded organizations on Bill S-216 and subsequently on the implementation of the BIA. Imagine Canada is grateful for Senator Omidvar’s unwavering support of charities. 

Imagine Canada was disappointed that the third amendment about directed funding did not pass. Senator Omidvar’s office will continue to work with Minister Freeland’s office to ensure that the CRA has a light touch when it comes to auditing pooled giving.

Imagine Canada will continue to monitor the CRA’s Guidance documents to ensure that the spirit of S-216 is reflected there.


In the April 2022 federal budget, the government announced that it would revise the legislation related to how charities work with non-qualified donees to ensure that it reflected the ‘spirit of Bill S-216’. When the text of the BIA was released, it was clear that there was a disconnect between the objective expressed in Budget 2022 and the proposed revisions to the Income Tax Act. As a result, the sector mobilized to seek changes.

In May, a group of charitable organizations and non-qualified donees, including Network for the Advancement of Black Communities, Cooperation Canada, and Philanthropic Foundations Canada, went to Ottawa to advocate for amendments to the BIA. The BIA’s language introduced an alternate route to pass the spirit of Senate Bill S-216, The Effective and Accountable Charities Act, originally introduced by Senator Ratna Omidvar. 
While aiming for the spirit of Bill S-216, the BIA introduced different language and, as such, would have led to confusion and challenges for organizations to fulfill their charitable purpose and for NQDs to enter into more equitable partnerships. Imagine Canada was proud to partner with the group of charitable organizations and non-qualified donees to ensure these two amendments passed. 

For more information on this advocacy, please see Imagine Canada’s press release.