“PPDDA” In, “Political Activities” Out: CRA’s New Draft Guidance on PPDDA Open for Comment
Jan 2019 Charity & NFP Law Update
On December 13, 2018, the omnibus Bill C-86, Budget Implementation Act, 2018, No. 2 (“Bill C-86”) received Royal Assent and modified the rules in the Income Tax Act (“ITA”) concerning “political activities” by registered charities and registered Canadian amateur athletic associations. In doing so, Bill C-86 removed reference to political activities from the ITA, including the quantitative limits on non-partisan political activities in particular, and instead introduced the concept of “public policy dialogue and development activities” (“PPDDAs”). Although the Bill C-86 amendments were well received by the charitable sector, they did not include a definition of PPDDAs. In the wake of the amendments, the Canada Revenue Agency (“CRA”) released a substantive and carefully written draft administrative guidance CG-027, Public policy dialogue and development activities by charities (the “Draft Guidance”) on January 21, 2019, shedding some light on its interpretation of PPDDAs and how it may administer the new rules. Further information on Bill C-86’s application to political activities and PPDDAs has also been published by the CRA on a new Questions and Answers webpage, released simultaneously with the Draft Guidance (“PPDDA Q&A”). This Charity & NFP Law Bulletin provides a summary of the Draft Guidance and its impact on charities.
For the balance of this Bulletin, please see Charity & NFP Law Bulletin No. 438.