1.Must
not be a charity
•If CRA considers an organization to be a "charity“ as defined in subsection 149.1(1), then it cannot qualify in that period as a tax-exempt NPO
•No explicit opinion from CRA is required and no ruling would be issued because it is always a question of fact (Document 2009-03299)
•If an NPO is denied charitable registration, this does not automatically mean that it is not a charity
•Document 2010-0380581I7 - an organization with exclusively
charitable purposes does not qualify as an NPO, even if it is not a
registered charity
•