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–This modified definition could impact charities carrying on activities outside of Canada where their programs in a foreign jurisdiction include a “related business” activity permitted under the ITA, or a charitable program that involves an inherently commercial element, such as microfinance
•A second important amendment will repeal the “facilitation payment” exemption provision of the Corruption of Foreign Public Officials Act on a date to be fixed by order of the Governor in Council
–Currently, such facilitation payments are excluded from the prohibition on bribery
–As a result, in the future, charities could be exposed to possible criminal liability for activities which, up to now, have been permitted
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