1. WELCOME

Welcome to the 1999 Annual Church & the Law Seminar, a practical seminar for churches and religious charities. This is the sixth year that the Annual Church & the Law Seminar has been held. This year's seminar is designed to provide an understanding of current legal issues that are relevant to churches and religious charities to better equip them to avoid legal problems before they occur, as well as to explain how recent legal developments can impact churches and religious charities in their day to day operations.

The seminar is hosted by Wardlaw, Mullin, Carter & Thwaites, a law firm with experience in advising churches and religious charities. The seminar is intended to provide a practical discussion of legal issues, and as such, a time to answer questions that may not have been addressed during the presentations will be set aside at the end of the day.



2. REGISTRATION


If you have registered, please obtain your name tags in the upstairs lobby. If you have not registered, then please complete a registration form and leave it at the registration table in the upstairs lobby together with a cheque for the $10.00 registration fee payable to Wardlaw, Mullin, Carter & Thwaites to help partially cover the cost of the facilities, coffee, muffins, and photocopies. If you have registered, but not paid your registration fee, please leave a check for $10.00 payable to the firm at the registration table in the upstairs lobby.

3. LUNCH


While complimentary coffee is provided throughout the day and muffins in the morning, lunch is on your own. Caterers will have assorted sandwiches, vegetables and dip, pickles, assorted cookies, fresh fruit, coffee, tea and juice at a cost of $6.00 (taxes included) for those who wish to stay at the church during the lunch period. Lunch tickets can be purchased near the registration table before the presentation begins, during the morning coffee break or at noon. Given the short lunch period, of 45 minutes, you are encouraged to buy your lunch tickets before the lunch break.



4. RESOURCE MATERIALS AVAILABLE ON THE WEB


Numerous articles, seminar materials, and newsletters of interest to Churches and religious charities, including back issues of Church & the Law Update and Charity & the Law Update are available at our web site at www.wardlaw.on.ca.









5. ACKNOWLEDGMENTS


We wish to gratefully acknowledge and thank the pastors, leadership, and congregation of Bramalea Baptist Church for the generous use of their facilities. The Church has requested that food and beverages be consumed only on the lower level and not in the sanctuary or lobby area.

We would like to also acknowledge the contributions from Carl Juneau, Professor Margaret Ogilvie, Wolfe Goodman, Jill McAlpine and Terence Sellen as guest speakers at this year's seminar. All speakers have given of their time free of charge.







6. AGENDA




8:00 a.m. Registration, Coffee and Muffins

8:45 a.m. Opening Remarks and Prayer

8:50 a.m. -Update on Recent Legal Developments

Affecting Churches and Charities Patricia L. Sproule Ward

9:20 a.m. -New Directions in the Definition of Charities

including Supreme Court of Canada Decision Wolfe D. Goodman

9:45 a.m. -Morality Issues for Christian Charities -

Where do the Courts Stand? David Thwaites

10:15 a.m. -Charitable Giving Techniques for Religious Charities Jill McAlpine

10:45 a.m. Information on Forum for Religious Charities Bonnie Green

10:50 a.m. Morning Coffee Break (15 minutes)

11:05 a.m. -National and International Charitable Structure:

Achieving Protection and Control Terrance S. Carter

11:35 a.m. -Who Do You Say That You Are? -

Courts, Creeds and Christian Identity Margaret Ogilvie

12:20 p.m. Lunch (on your own)

1:05 p.m. -Christian Mediation - Peacemakers in the Church Terence Sellen

1:35 p.m. -The Y2K Crisis: Practical Steps to Avoid Legal Liability Terrance Carter

2:05 p.m. -Identifying and Avoiding Legal Issues and

Liability on the Internet Mervyn White

2:35 p.m. -Is The Sky Really Falling? - Revenue Canada's Position

on Donor Benefits and Christian Charities Carl Juneau

3:15 p.m. Program Formally Ends

3:15 p.m. Questions and Answers for those who wish to remain







7. SPEAKERS (in alphabetical order)


TERRANCE S. CARTER

Mr. Carter practices primarily in the area of charities, not-for-profit organizations, trade-marks and gift planning, with particular experience involving religious organizations. He is a partner with the firm of Wardlaw, Mullin, Carter & Thwaites in Orangeville, Ontario and is a registered Trade-Mark Agent. He obtained a BA(Jt. Hon.) from McGill University and his LL.B. from Osgoode Hall Law School in Toronto. Mr. Carter is chair of the Charity and Not-For-Profit Law Section of the Canadian Bar Association (Ontario). He has written numerous articles for various journals and publications and is a frequent speaker at seminars on legal issues involving charities and not-for-profit organizations in numerous cities across Canada. Mr. Carter is the editor of and a contributor to Charity & the Law Update, distributed across Canada by The Canadian Centre for Philanthropy, and Church & the Law Update, and is Chair of the Church & the Law Seminar held each year for religious charities. He has also participated in consultations with the Charities Division of Revenue Canada and the Public Guardian and Trustee of Ontario.

WOLFE D. GOODMAN, Q.C.

Mr. Goodman was born and educated in Toronto. He graduated in Commerce and Finance from the University of Toronto in 1946 and from Osgoode Hall Law School in 1949. He is a senior partner in Goodman and Carr in Toronto specializing in Taxation and Estate Planning. He was on sabbatical in 1975-1976 to pursue his graduate studies leading to a degree of Doctor of Juridical Science, 1976, and publication of "International Double Taxation of Estates and Inheritances", 1978. He was the Governor of the Canadian Tax Foundation in 1973 to 1975 and he was appointed by the Minister of Finance as Chairman of Federal Sales Tax Review Committee in 1983. He has lectured in the Faculty of Law at the University of Toronto on Accounting in Law in 1961-1969 and on Estate Planning in 1969-1964. General Editor of "Goodman on Estate Planning", published by Federal Press, Montreal. He has also written extensively on taxation and estate planning for over 40 years, with articles published in various tax and estate planning journals and accounting magazines and a frequent speaker on these topics. He is a member of the Canadian Bar Association, the International Bar Association, the Canadian Tax Foundation, the International Fiscal Association, the International Academy of Estate and Trust Law and the American Academy of Estate and Trust Counsel.

CARL JUNEAU

Mr. Juneau is a member of the Bar Association of the Province of Quebec since 1980. He has been with the Charities Division at Revenue Canada since 1983, and since 1986, he has been Assistant Director of the Charities Division in charge of Technical Interpretations. As such, he is directly involved in policy formulation in amendments to the Canadian Income Tax Act as it relates to charities and in substantive decisions relating to the registration or revocation of charities under the Act. Mr. Juneau participates extensively at charities conferences, internationally and throughout Canada, both to explain and to consult on Revenue Canada's role as it relates to charities. Notably, he has spoken at conferences in India, South Africa, Australia and Estonia, on issues of charity and taxation, as well as at Seminars for the Law Society of Upper Canada and the Canadian Bar Association.

JILL H. McALPINE, C.A.

Ms. McAlpine is a chartered accountant with PricewaterhouseCoopers in North York, and has extensive experience in devising and implementing creative gifting plans. She also advises charities and other not-for-profit organizations on a wide range of organizational and operational issues. She also makes frequent presentations at major charities conferences (eg, the Canadian Association of Gift Planners, the National Society for Fund-Raising Executives, the Association for Health Care Philanthropy, the Ontario Hospital Association, and the Community Foundations of Canada, among others). She is currently a member of the Board of Directors of the Toronto Community Foundation and Community Foundation of Canada; a member of the Professional Advisory Councils of the North York General Hospital Foundation and the Canadian Diabetes Association; and is a consultant to PricewaterhouseCoopers.



PROFESSOR MARGARET OGILVIE

M.H. Ogilvie is a Professor of Law at Carleton University in Ottawa. She is a graduate of Trinity College, University of Toronto (B.A.), Dalhousie University (LL.B.) and the University of Oxford (M.A., D. Phil.) and a member of the Bars of Ontario and Nova Scotia. She has been a visiting Professor at the Universities of Edinburgh, Oxford and Toronto and is the author of 10 books, including Religious Institutions and the Law in Canada (Carswell, 1996), and the editor of two student course texts, as well as over 200 articles, comments and reviews in various Canadian and international law journals. Dr. Ogilvie is currently a member of the editorial boards of four law journals, including the Journal of the Church Law Association, and has given expert legal advice to a variety of churches and their legal counsel on a wide range of legal issues. She was elected a Fellow of the Royal Society of Canada in 1993; awarded the David W. Mundell Medal in 1996 for distinguished contributions to law and literature; and awarded the degree of Doctor of Divinity (honoris causa) by The Presbyterian College, Montreal in 1998. She is a member of Knox Presbyterian Church, Ottawa.

TERENCE SELLEN

Mr. Sellen is the Executive Director of Christian Legal Fellowship. He is a graduate of the University of Manitoba Law School. He also has diplomas in Comparative Law from Laval University in Quebec as well as the University of Ottawa. He is active in Christian Ministry with the Fellowship of Christian Assemblies, he has also enjoyed working with the legal profession through the EduLaw Professional Development Program. He has also been doing workshops and seminars on church peacemaking from Nova Scotia to British Columbia since 1995. He may be contacted at: Christian Legal Fellowship, Box 1, Group 14, Oakbank, MB Canada, R0E 1J1, Phone: (204) 228-3445, Fax: (204) 444-2202 or (800) 442-8850.

DAVID G. THWAITES

Mr. Thwaites has been a lawyer since 1981 in Ontario practicing in partnership at Wardlaw, Mullin, Carter & Thwaites in Orangeville, Ontario. He obtained his LL.B. in 1979 at The University of Western in London, Ontario. His practice is as a litigation lawyer providing counsel in the areas of insurance law, employment law, Church discipline, and family law. He has provided counsel to numerous Church and para-Church organizations and to individuals in the Christian marketplace. He is counsel to The Children's Aid Society of the County of Dufferin. He has lectured at numerous seminars sponsored by the Law Society of Upper Canada, the Canadian Bar Association and The Canadian Council of Christian Charities and contributed articles to the Church and the Law Update regularly on topics including Church Liability, Employment Law and Human Rights. He is a member of the Canadian Bar Association (Ontario) Council and The Christian Legal Fellowship.

PATRICIA L. SPROULE WARD

Mrs. Ward is a partner with the law firm of Wardlaw, Mullin, Carter & Thwaites, Orangeville, Ontario. Mrs. Ward received her B.B.A. (Honours) at Wilfrid Laurier University (1983), her LL.B. at the University of Windsor (1986), and was called to the Bar in 1988 when she joined Wardlaw, Mullin, Carter & Thwaites. During her practice, Mrs. Ward has concentrated in the areas of wills, powers of attorney, estates, charities municipal law and real estate,. She is associate Counsel for the Children's Aid Society of the County of Dufferin and associate counsel for a number of municipalities. She has acted on behalf of various Churches and other charities. Mrs. Ward has been an annual speaker at the Church and the Law Seminar as well as a contributor for seminars provided for clients and community groups. She has also written for Municipal World Magazine and most recently taught the Real Estate Course for the Institute of Law Clerks through Georgian College.

MERVYN F. WHITE

Mr. White is a lawyer with the law firm of Wardlaw, Mullin, Carter & Thwaites in Orangeville, Ontario. Mr. White received his Bachelor of Arts (Honours) at Guelph University and his Bachelor of Law at York University, Osgoode Hall, and was called to the Bar in February of 1995. Since commencing practice, Mr. White has gained experience in a number of areas of law, including civil and criminal litigation, as well as corporate/commercial law. Mr. White also practices in the field of intellectual property law, having a special interest in both trade-mark and copyright law, as well as in internet related matters.



8. QUESTIONS


Questions are encouraged and will be answered at the end of the day for those who would like to remain. A question sheet is contained at the back of this handout and should be left at the front lectern in the auditorium.

9. RISK MANAGEMENT APPROACH FOR TOPICS PRESENTED


To effectively use the information presented at the Seminar today, it is suggested that the following risk management approach be taken in relation to the legal issues that will be presented:

1. Become familiar with the relevant law concerning an issue

2. Apply that knowledge of the law to a particular fact situation to determine if a risk exists that requires steps be taken

3. Report back to the church or charity on the issue to be addressed

4. Become pro-active in reducing the risk before it becomes a problem

5. Monitor progress in addressing the issue to ensure that it is dealt with

6. Keep abreast of changes in the law

10. YOUR HOSTS


WARDLAW, MULLIN, CARTER & THWAITES

Barristers & Solicitors

"Established in 1896"


235 Broadway, P.O. Box 67

Orangeville, Ontario, L9W 2Z5

Telephone (519) 941-1760

Fax (519) 941-3688

E-Mail tcarter@wardlaw.on.ca

Web Site www.wardlaw.on.ca

A firm experienced in dealing with church and charity related legal issues directed at avoiding problems before they occur through effective legal risk management, including assistance with:

Church Constitutions

and Incorporation

Charitable Foundations

Legal Risk Management

Denominational Issues

Gift Planning

National and

International Structures

Church Discipline

Sexual Abuse Policies

Copyright and Licencing

Charitable Registrations

Employment Issues

Litigation Counsel

Trade-Mark Protection

Insurance Issues

Church Development

Domain Name Issues

11. DISCLAIMER


The material contained in the seminar is provided for information purposes on the understanding that neither the firm of Wardlaw, Mullin, Carter & Thwaites nor any of the lawyers or professionals involved in the seminar are rendering legal advice or establishing a solicitor/client relationship. None of the information provided in this seminar should be relied upon for legal decision making without first consulting with your legal counsel and obtaining a written opinion concerning the specifics of a particular situation.

handout.99

* Church & the Law is a T.M. of Wardlaw, Mullin, Carter & Thwaites






1999 ANNUAL CHURCH & THE LAW SEMINAR

Legislative & Caselaw Developments

that Affect Churches and Charities


Wednesday February 3rd, 1999


by Patricia L. Sproule Ward, B.B.A., LL.B.©

Wardlaw, Mullin, Carter & Thwaites

Barristers, Solicitors & Trade-Mark Agents

235 Broadway,

Orangeville, Ontario, L9W 2Z5

Telephone: (519) 941-1760 Fax: (519) 941-3688

E-Mail: psprouleward@wardlaw.on.ca

Web Site: www.wardlaw.on.ca






A. LEGISLATIVE UPDATE

1. ESTATE ADMINISTRATION TAX ACT, 1998 (Ontario)





2. SMALL BUSINESS AND CHARITY'S PROTECTION ACT (Ontario)

  • Allows landlords who rent commercial or industrial property pursuant to gross leases to pass on part of the real property taxes as additional rent

  • Need to meet specific requirements, including proper Notice, in order to collect the additional rent or to have to pay the additional rent

  • Notice of intent to charge this additional rent must have been given prior to December 15th, 1998

  • Cap on amount of tax that can be passed on as Landlord's may qualify for a rebate of a portion of the realty taxes



    3. LOBBYISTS REGISTRATION ACT, 1998 (Ontario)

  • Came into effect on January 15th, 1999

  • Requires all persons who meet definition of lobbyist to register themselves and their activities with the Lobbyists Registration Office

  • Three categories of lobbyists

    - Consultant Lobbyists paid to lobby on half of a client, includes professionals who provide lobbying services for their clients

    - In-house Lobbyists employed by persons, corporations and partnerships that carry on commercial activities for financial gain

    - In-house Lobbyists employed by non-commercial organizations such as advocacy groups and industry, professional and charitable organizations

  • Defines lobbying to occur when a paid lobbyist communicates with a public office holder in an attempt to influence

    - development of any legislative proposal by a Member of the Legislative Assembly;

    - introduction, passage, defeat or amendment of any bill or resolution;

    - the making or amendment of any regulation;

    - the development, amendment or termination of any policy or program;

    - any decision about privatization or outsourcing;

    - awarding of grants or financial benefits by or on behalf of the Crown (consultant lobbyists only); and

    - the arrangement of meetings between a public office holder and any other person (consultant lobbyists only).

  • Fines of up to $25,000.00 may be imposed for failure to comply with terms of the Act

    4. TRUSTEE ACT (Ontario)

  • Bill 25 amending the Trustee Act (Ontario) received third reading November 30th, 1998.

    - Bill 25 will be proclaimed in force on a day to be announced, the reform not yet law

    - Bill 25 will replace the current statutory list of permitted investments (ie G.I.C's) with a "prudent investor rule"

    - investments in mutual funds will be permitted but only after Bill 25 is proclaimed

    - Bill 25 will place a more onerous responsibility for investments on directors

    - There will be no relief available for technical breaches of trust as is presently the case

  • See attached Church & the Law Update Volume II, Number 2 for a more complete discussion of investment powers for Trustees.

    5. CANADA CORPORATIONS ACT (Federal) - Changes to Federal Non Profit Corporate Law Policy

  • Industry Canada amended its administrative policy for non-share capital corporations under Part II of the Canada Corporations Act in April, 1998.

  • Amendments will include making it easier to hold telephone conference calls for board and member meetings

  • It is important to review and update general operating by-laws for all charities that have been incorporated federally and the Canada Corporations Act



    B. CASELAW UPDATE

    1. HUMAN LIFE INTERNATIONAL IN CANADA INC. V. M.N.R., Federal Court of Appeal, Docket A-288-94, Judgement dated March 18, 1998, leave to appeal to Supreme Court of Canada, denied January 21st, 1999

  • According to the Ministry of Revenue, this registered charity was primarily involved in promoting its own views on many issues including, abortion, sex education in schools and universal day care

  • Ministry of National Revenue issued a notice of intent to de-register the organization as a charity because it felt that its activities were mostly political and not charitable in that they were attempting to affect public opinion with respect to a number of "social" issues

  • Court of Appeal deemed the organizations activities to be substantially political. This was appealed to the Supreme Court of Canada which dismissed the appeal.

  • Confirms that not only must objects be charitable but the also the activities carried out to attain those objects must also, substantially, be considered charitable



    2. VANCOUVER SOCIETY OF IMMIGRANT AND VISIBLE MINORITY WOMEN v. M.N.R. [1996] No. 290, [1999] S.C.C. File #25359

  • Case was head by the Supreme Court of Canada in February, 1998, and a decision was rendered on January 29th, 1999

  • The Appellant lost the appeal to become a registered charity by a four\three split of the Supreme Court but the Court broadened the scope of "advancement of education" as a head of charity

  • The decision emphasises the importance of lawyers' carefully drafting the charitable objects clause of a charity

    3. ALLIANCE FOR LIFE

  • Received Notice of Intent to de-register based on perception that the non-charitable organization named "Alliance Non-Profit Pro-Life Action Inc." which carried out the political activities was an integral part of the charitable operations of Alliance for Life

  • Originally this arrangement was approved but concern that the two organizations are too closely related

  • Waiting for the decision of the Federal Court of Appeal



    4. CHRISTIAN BROTHERS OF IRELAND IN CANADA (Re), (1998), 37 O.R. (3d) 367, 21 E.T.R. (2d) 93 (Gen.Div.)

  • Important decision of the Ontario Court (General Division) dealing with what assets of the charity can be used to satisfy judgements against it

  • Court looked at definition of what constituted a donor-restricted trust fund which would then place the asset out of reach of creditors

  • Determined that for a true donor-restricted gift certain formalities must be complied

  • Public appeals for funds for a particular purpose are not considered to be a donor-restricted fund and therefore could be available to satisfy creditors

  • See an article by T. Carter on Donor Restricted Charitable Gifts: A Practical Overview @ www.wardlaw.on.ca for a more complete analysis of the consequences of the Christian Brothers decision.

    DISCLAIMER: This Legislative & Caselaw Developments That Effect Churches and Charities is distributed with the understanding that it does not constitute legal advice or establish the solicitor/client relationship by way of any information contained herein. The contents are intended for general information purposes only and under no circumstances can be relied upon for legal decision making without first consulting with a lawyer and obtaining a written opinion concerning the specifics of your particular situation.

    Wardlaw, Mullin, Carter & Thwaites

    Barristers, Solicitors & Trade-Mark Agents

    "Established in 1896"

    235 Broadway, P.O. Box 67

    Orangeville, Ontario, L9W 2Z5

    Telephone:(519) 941-1760, Fax:(519) 941-3688

    E-Mail - psprouleward@wardlaw.on.ca

    Web - www.wardlaw.on.ca

    tsc/seminar/chu&law99/trish





















    1999 ANNUAL CHURCH & THE LAW SEMINAR

    Morality Issues For Christians -

    Where do the Courts Stand?

    Wednesday, February 3rd, 1999


    by David G. Thwaites, L.L.B.

    Wardlaw, Mullin, Carter & Thwaites

    Barristers, Solicitors & Trade-Mark Agents

    235 Broadway Avenue

    Orangeville, Ontario, L9W 2Z5

    Telephone: (519) 941-1760 Fax: (519) 941-3688

    E-Mail: dthwaites@wardlaw.on.ca

    Web Site: www.wardlaw.on.ca


    A. INTRODUCTION

    B. THE COURTS - FREEDOM, RIGHTS AND MORALITY

  • "It is not every evil which attracts Court action; some evils remain for the legislature to correct"

  • Madam Justice McLauchlin, Winnipeg Family Services vs. G.(D.F.) (S.C.C.)

    C. RIGHT TO LIFE - WHEN DO "RIGHTS" COMMENCE?

  • Tremblay v. Daigle (1989): foetus is not a legal person

  • Winnipeg Family Services v. G.(D.F.) (1998):

    - law does not recognize an unborn child as a legal person

    - the rights or interest of the unborn remain inchoate and incomplete until birth

    - it is for the legislature, not the Courts, to change the law when the revision is major and the ramifications are complex

    - the Courts have determined only the legal status not the biological or spiritual status of the unborn

  • Dobson v. Dobson (1997) (S.C.C. decision pending)

    - a child may sue parents for pre-natal injuries resulting from a motor vehicle accident

  • Morgantaler v. R (1988)

    - protection of the foetus is a perfectly valid legislature objective recognizing that it is a potential life from the moment of conception





    D. RIGHT TO DIE - When Does One Have the Right to Make that Choice?

  • Rodriquez v. British Columbia (Attorney General) (1993)

    - it is a criminal offence for a person to assist suicide

    - human life is sacred and inviolable

    - sanctity of life excludes freedom of choice in the self-infliction of death

    - the purpose of state policy is to protect the vulnerable and not to depreciate life

    - to participate in the ending of a life is intrinsically morally and legally wrong

  • Regina v. Latimer (1998) (on appeal to Supreme Court of Canada)

    - state has obligation to protect the vulnerable

    - surrogate decision-makers do not have the authority to make life and death decisions

  • Sawatzky v. Riverview Health Centre (1998)

    - "do not resuscitate" order

    - Doctor does not have the right to make decisions based on 'no benefit to continue life' of a patient

    E. RIGHT TO DISCRIMINATE

    1. DOES RELIGIOUS BELIEF AFFORD THE ABILITY TO DISCRIMINATE?

  • Ontario Human Rights Code

    - prohibits discrimination based upon various grounds including "creed", "sexual orientation" and "marital status"

    - exception, s. 24 Code in area of employment if nature of employment tied to religious belief

    - intent to discriminate not relevant

    2. WHAT PLACE DOES 'RELIGION' HAVE IN THE PUBLIC EDUCATIONAL SYSTEM?

  • Zylberberg v. Sudbury Board of Education (1988) (Ont. C.A.)

    - religious exercises infringed freedom of religion

    - there are alternative ways to impart educational and moral values

  • Can. Civil Liberties and Minister of Education (1990) (Ont. C.A.)

    - religious education amounted to indoctrination and infringed freedom of religion

  • Chamberlain v. Surrey School Board (1998)(BCSC) (appeal pending)

    - the School Board is to decide educational issues on secular principles only, exclusive of any value consideration if professed by persons with religious belief





    3. DO THE RELIGIOUS BELIEFS OF A "SCHOOL" MEAN STUDENTS WILL DISCRIMINATE?

  • Trinity Western Univ. v. B.C. College of Teachers (1998) BCCA.

    - no evidence presented by College of Teachers of discrimination

    - freedom of expression

    - freedom of religion

    F. FREEDOM OF EXPRESSION

  • Freedom of expression and the contemporary community standard of tolerance

    - Regina v. Langar (1995) (child pornography)

    - Region v. Sharpe (1999) (child pornography)

    - Mara and East v. Regina (1997) (indecency)

    - Regina v. Jacob (1996) (indecency)

  • In the context of advocating pro-life or anti-homosexuality?

    G. CONCLUSION

  • Be informed

  • Be pro-active not reactive

  • Be supportive







    DISCLAIMER: This summary of Web Site Issues: Morality Issues for Christians - Where do the Courts Stand is distributed with the understanding that it does not constitute legal advice or establishing the solicitor/client relationship by way of any information contained herein. The contents are intended for general information purposes only and under no circumstances can be relied upon for legal decision making without first consulting with a lawyer and obtaining a written opinion concerning the specifics of your particular situation.


    Wardlaw, Mullin, Carter & Thwaites

    Barristers, Solicitors & Trade-Mark Agents

    "Established in 1896"

    235 Broadway, P.O. Box 67, Orangeville, Ontario, L9W 2Z5

    Telephone:(519) 941-1760 Fax:(519) 941-3688

    E-Mail: dthwaites@wardlaw.on.ca

    Web Site: www.wardlaw.on.ca


    mg/tsc/seminars/ch&law99/david













    1999 ANNUAL CHURCH & THE LAW SEMINAR

    National and International Charitable Structures:

    Achieving Protection and Control

    Wednesday, February 3rd, 1999

    Terrance S. Carter, B.A., LL.B.

    & Trade-mark Agent

    Wardlaw, Mullin, Carter & Thwaites

    Barristers, Solicitors & Trade-mark Agents

    235 Broadway, P.O. Box 67

    Orangeville, Ontario, L9W 2Z5

    E-Mail - tcarter@wardlaw.on.ca

    Web Site - www.wardlaw.on.ca

    Telephone: (519) 941-1760 Fax: (519) 941-3688


    A. INTRODUCTORY COMMENTS

  • Charities seldom give sufficient attention to organizational structural issues, particularly as they relate to national or international structures

  • There is frequently a difference between how the charity actually operates and the legal organizational documentation for the charity

  • This dichotomy can eventually result in potential confusion and possibly even litigation

  • Avoiding exposure to liability and maintaining effective control over the goodwill of a charity are dependent upon putting an effective organizational structure in place that reflects how the charity operates

  • All Charities should review their organizational structure on a regular basis

  • Charities that operate on a national or international basis particularly need to evaluate the effectiveness of their organizational structure to protect their assets and maintain control over member organizations

  • Structural issues are relevant for any charity that is a part of a larger organization

  • See www.wardlaw.on.ca for more details on this topic in a paper entitled National and International Charitable Structures: Achieving Protection and Control

    B. THE NATURE OF A NOT-FOR-PROFIT CHARITABLE

    CORPORATION AND THE NEED FOR CONTROL

    1. THE RELEVANCY OF THE NOT-FOR-PROFIT CORPORATION

  • Not every not-for-profit corporation is a charity, ie, a golf club is a not for profit corporation but is not a charity

  • Every charitable corporation, though, must by definition be a not-for-profit corporation

  • A not-for-profit corporation is distinctive from a profit making corporation because it has members instead of shareholders

    2. THE LACK OF EQUITY IN A NOT-FOR-PROFIT CORPORATION AND THE CORRESPONDING NEED FOR CONTROL

  • A not-for-profit corporation does not permit equity ownership in the company through the issuance of shares and therefore cannot be controlled by another corporation by the ownership of shares

  • A not-for-profit corporation is controlled through its members, but the members cannot own the corporation through the purchase of shares

  • The control mechanisms for not-for-profit corporations must instead be created through establishing effective contractual relationships

    C. NATIONAL CHARITABLE STRUCTURES

    1. THE NATURE OF A NATIONAL CHARITABLE ORGANIZATION

    (a) The Basic Character

  • A national charitable organization generally has operations that extend beyond the boundaries of one province but can also apply in the same province

    (b) The Distinction Between the National Chapter Model and the National Association Model

    (i) The National Chapter Model (ie. a single charity with chapters)

    (ii) The National Association Model (ie, many independent charities are associated with each other)











































    (c) Confusion Between the National Chapter Model and the National Association Model

  • Many religious charities operate without knowing whether they are organized as a National Chapter Model (ie, a single charity) or a National Association Model (ie, many independent charities)

  • This may result in confusion and increased potential for legal action , particularly with estate gifts

  • Where a National Association Model is utilized without adequate control provisions in place, it may result in the loss of control of a "renegade" member organization

    (d) The Pros and Cons of the National Chapter Model

    (i) The Pros of the National Chapter Model

  • Higher degree of control can be exercised over chapters and branches

  • Greater simplicity in operation on a national basis

  • No risk of losing control over the assets and goodwill of the national charity to a renegade member organization

    (ii) The Cons of the National Chapter Model

  • Any liability claim against a chapter or branch will expose all of the assets of the national organization and its chapters by a successful claimant ie, there will result a "deep pocket" for successful plaintiffs to claim against

  • Possibly increased expense from employment legislation, such as pay equity or employer health tax

    (e) The Pros and Cons of the National Association Model

    (i) The Pros of the National Association Model

  • Reduced liability exposure by containing liabilities within separate corporations

  • The liability risks of one member organization does not affect the assets of other member organizations or of the national governing association

  • A separate Ontario corporation created only for Ontario operations can limit the jurisdiction of the PGT under the Charities Accounting Act and the Trustee Act of Ontario to Ontario assets only

  • Reduced expenses under employment legislation, such as pay equity or employee health tax

    (ii) The Cons of the National Association Model

  • Increased complexity in maintaining effective control over member organizations

  • This could result in the loss of control over a "renegade" member organization

  • Potential loss by a national associations of its trade-mark rights through misuse by member organizations

  • Potential for confusion in determining whether the beneficiary of a charitable gift is a member organization or the national governing association

    (f) Comments Concerning Choice of Organizational Models

  • Increasing risks of litigation necessitates that the National Association Model be considered for charities involved in higher risk activities, for instance, where children ministries are involved

  • Charities that have low liability exposure may be better served through the enhanced control available from the National Chapter Model, provided that the increased costs from employment legislation is not too expensive



    2. THE STRUCTURE OF THE NATIONAL ASSOCIATION MODEL

    (a) Internal Structure of the National Governing Association

    (i) Federal vs. Provincial Incorporation

  • A national governing association should generally be incorporated as a federal corporation under the Canada Corporations Act

    (ii) Letters Patent Considerations

  • Objects need to be national in scope

  • Objects need to provide authority to establish and enforce national standards

  • Religious charities should include a statement of faith in its letters patent

  • Letters patent should include a broad investment power

  • Letters patent should include a "directed" dissolution clause in favour of a charity that has similar objects

    (iii) By-Law Considerations

  • Are different classes of membership required to reflect regional interests?

  • Is the election of directors to be done by corporate members or by nominees?

    (b) Control Considerations

    (i) The Need for Control

  • The National Association Model requires that control be exercised through internal corporate documentation for member organizations as well as contractual and/or licence arrangements between the national governing association and member organizations

    (ii) Ex Officio Control Method

  • The ex-officio control method involves representatives from the national governing association being "ex-officio" members of the board of member organizations

    (iii) Franchise Control Model

  • A franchisor/franchisee model utilized in a business context where a parent/subsidiary form of ownership of shares is not available can provide an effective model for a national governing association that is not able to control its member organization by "owing" the organization as a subsidiary

    (c) The Specifics of the Franchise Control Model

    (i) An Association Agreement for Member Organizations would include the following terms:

  • A requirement that there be similar charitable purposes

  • A statement that there be no partnership or joint venture arrangements

  • The length of term for the agreement with automatic renewals unless canceled

  • The basic requirements of the association relationship are specified

  • The rights that flow from the association relationship are specified

  • A statements of when the association relationship will be terminated and the consequences that flow from such termination

  • The inclusion of a conflict resolution provision through mediation and/or arbitration



    (ii) Incorporating Documentation for Member Organizations

  • Standard incorporating precedent materials could be attached as a schedule to the association agreement

  • The approval by the national governing association should be required for the incorporating documentation for a member organization

    (iii) Trade-Mark Considerations

  • The name and/or trade-marks of a charity is one of its most important assets and should be protected

  • A trade-mark registration should be made for key trade-marks

  • A trade-mark licence agreement is essential to protect a trade-mark by evidencing adequate control as required by the Trade-marks Act

    (iv) Copyright Considerations

  • There is a need to establish and/or clarify ownership of copyrights

  • There may also be a need for a copyright licence agreement with member organizations

    (d) Decentralization Through Utilization of the National Association Model

    (i) What is Meant by Decentralization?

  • Decentralization involves a National Chapter Model (single charity) converting into a National Association Model (multiple charities) to enhance liability protection of assets

  • Decentralization may be necessary if the national charity is involved in activities that have a high risk of exposure to liability, such as children ministries

    (ii) Considerations Involving the process of Decentralization

  • Need to properly document transfer of assets and liabilities in favour of each Member Organization

  • The transfer of real property should first require an environmental audit

  • The transfer of donor restricted trust funds needs to be documented and may require a consent order pursuant to the Charities Accounting Act

  • The terms of charitable trusts in old deeds must be complied with and will bind a subsequent transferee charity

    (e) "Piercing the Corporate Veil" and Multi-Corporate Liability

  • The concept of "piercing the corporate veil" could result in the assets of a national governing association being exposed to the liabilities of its member organizations

  • Ontario courts will not "pierce the corporate veil" unless there has been a complete domination by one corporation over the other corporation, as well as fraudulent or improper conduct, and damages result

  • Notwithstanding the narrow case law, steps should be taken to avoid even the possibility of "piecing the corporate veil" by separating the legal and operational aspects of the national governing association from that of its member organizations













    3. THE STRUCTURE OF THE NATIONAL CHAPTER MODEL

    (a) The Internal Structure

    (i) Preliminary Considerations

  • The national organization and the Chapter Model is both the governing body as well as the single legal entity that carries on operations throughout Canada (or on a provincial basis)

    (ii) Federal vs. Provincial Incorporation

  • A national organization based on a Chapter Model should be incorporated federally under the Canada Corporations Act

  • A national organizations that is currently incorporated provincially should be very careful before attempting to a convert federally by the incorporation of a new federal corporation

    (iii) Letter Patent Considerations

  • The charitable purposes need to be national in scope

  • The charitable purpose needs to authorize activities being carried out through divisions i.e., through chapters or branches

    (iv) By-Law Considerations

  • The organizational by-laws for chapters or branches should be included as part of the by-laws of the national organization

    (b) Establishing the Structure of a National Chapter Model

    (i) Utilizing a Chapter/Charter Agreement

  • The utilization of a chapter/charter agreement would recognize that a chapter or branch is an operating division of a single national organization

  • The expectations and limitations in the operations of a chapter or branch need to be set out in a chapter/charter agreement

    (ii) Licensing Considerations

  • Local chapters need limitations concerning when or how the trade-marks and copyrights of the national organization can be used

  • Licencing eliminates confusion over who owns trade-marks and copyrights

    (c) Liability Considerations Involving the National Association Model

  • The activities of a chapter or branch may expose all of the assets of a national organization as well as all of its chapters or branches to claims made against a single chapter or branch

  • A national organization should implement effective risk management policies and procedures for chapters and branches to protect both the national organization and all chapters and branches

    (d) Utilization of a Parallel Foundation for the National Chapter Model

  • A parallel foundation can be used to shelter assets of the national oganization and its chapters or branches

  • A parallel foundation can also be used to attract long term endowment funds







    D. INTERNATIONAL CHARITABLE STRUCTURES

    1. THE GENERAL NATURE OF AN INTERNATIONAL CHARITABLE ORGANIZATION

    (a) The Challenge of Operating in Multiple Jurisdictions on an International basis

  • The sovereignty in each country requires that international operations be carried out through independent and autonomous charitable organizations in each country

    (b) The Dichotomy Between National and International Operations

  • Confusion can result from the founding charity in one country acting as both the international parent as well as the domestic charity

  • Confusion can result from the founding charity (often in the U.S.) attempting to impose its organizational structure and precedents on member domestic charities

    (c) Funding Issues with Revenue Canada Involving the Transfer of Monies Outside of Canada

  • A Canadian registered charity must carry on charitable activities itself or through "qualified donees", otherwise the activities done through foreign charities must be carefully done in accordance with arrangements acceptable to Revenue Canada

  • Transfer of monies to "non-qualified donees" requires that there be either an agency relationship, joint venture arrangement or co-operative partnership

    2. OPTIONS IN STRUCTURING AN INTERNATIONAL ORGANIZATION

    (a) Multiple Association Model



















































    (b) Subsidiary Model

    (c) Separate International Organization Model

    3. THE GENERAL STRUCTURE OF A SEPARATE INTERNATIONAL CORPORATION

    (a) The Benefits of a Separate International Organization

  • - a separate international organization separates the international operations from the control of the founding charity

  • this permits better representational input from member domestic charities



  • it also permits a central entity to own and control key assets on an international basis, such as trade-marks

    (b) Where to Incorporate a Separate International Corporation

  • Need to choose a stable county in which to incorporate

  • International operational purposes needs to be recognized as being charitable at law

    (c) Letters Patent Considerations

  • The charitable objects need to be international in scope and authorize the establishment and implementation of international standards

  • Religious charities should include statement of faith in the letters patent

  • The letters patent should include a direct dissolution clause in favour of a charity with similar objects

    (d) By-Law Considerations

  • Who are to be the corporate members?

  • Possible need to reserve veto rights in favour of the founding charity

  • Is the election of directors to be done by corporate members or nominees from member organizations?

    4. IMPLEMENTING EFFECTIVE INTERNATIONAL CONTROL PROVISIONS

    (a) The Importance of Developing International Control Provisions

  • The lack of control provisions can result in a potential renegade domestic charity

  • Effective strategic planning in international structure can avoid conflict, loss of control, and potential litigation

    (b) Utilizing the Franchise Control Model

  • There should be a single entity to act as the "franchisor" with each domestic charity acting as a "franchisee"

  • Control can be effected through contractual and/or licencing arrangements between the "franchisor" and each domestic charity

    (c) The Specifics of the Franchise Control Model on an International Basis

    (i) The International Association Agreement would include:

  • A statement of the international expectations for domestic charities

  • An explanation of circumstances leading to the termination of the International Association Agreement

  • The consequences from loss of association status would include the loss of the right to use the trade-mark and copyrights in the country of the domestic charity

    (ii) Incorporating Documents of the Domestic Charity would include:

  • The general terms of charitable purposes consistent with international charity

  • A statement of faith consistent with international charity

  • A right of approval of the international charity over changes in the constating documents of the domestic charity

  • The requirement for ex-officio participation of the international charity on the board of directors of the domestic charity

    (iii) Trade-Mark Licensing Considerations

  • The need to register trade-marks in each country that the international charity operates in

  • The international charity should be the owner of the trade-marks in each country and then licence the trade-marks to the domestic charity

  • The international charity needs to register internet domain names using as many domains as possible to "occupy the field" and preclude "domain squatting" by others

  • The international charity should also register geographic internet domain names for each country and then licence them to applicable domestic charities

  • Trade-mark applications in some countries can be based on proposed use as well as actual use of the trade-mark

  • A domestic charity may need to assign its trade-mark rights in favour of the international charity if the domestic charity has already acquired rights in the trade-mark

    (iv) Copyright Considerations

  • Ownership of copyrights need to be clarified between international and domestic charities

  • The international charity may need to establish licence agreements for copyrights being used by domestic charities

    (v) Enforcing Control Provisions

  • Control provisions are of little value unless they are enforced

  • "Use it or loose it" applies to the time sensitive nature of protecting intellectual property rights

    5. LIABILITY ISSUES IN INTERNATIONAL OPERATIONS

    (a) Exposure to Liability

  • Agency and/or co-operative partnerships may lead to joint and several liability

  • Multiple corporations may lead to liability if there are circumstances where the "corporate veil is pierced"

    (b) International Risk Management Considerations

  • It is important to review insurance policies for geographic limitations and the designation of the international charity and the domestic charities as co-insured

  • The need to allocate risk and utilize a release and/or indemnification agreement

    DISCLAIMER: This National and International Charitable Structures: Achieving Protection and Control is distributed with the understanding that it does not constitute legal advice or establish the solicitor/client relationship by way of any information contained herein. The contents are intended for general information purposes only and under no circumstances can be relied upon for legal decision making without first consulting with a lawyer and obtaining a written opinion concerning the specifics of your particular situation.

    Wardlaw, Mullin, Carter & Thwaites

    Barristers, Solicitors & Trade-Mark Agents

    235 Broadway, P.O. Box 67"Established in 1896"

    Orangeville, Ontario, L9W 2Z5

    Telephone:(519) 941-1760, Fax:(519) 941-3688

    E-Mail - tcarter@wardlaw.on.ca

    Web - www.wardlaw.on.ca

    tsc/seminar/chu&law.99/national&international









    1999 ANNUAL CHURCH & THE LAW SEMINAR

    PEACEMAKERS IN THE CHURCH

    Wednesday, February 3rd, 1999

    Terence Sellen

    Christian Legal Fellowship

    Box 1, Group 14

    Oakbank, Manitoba, R0E 1J1

    E-Mail - direct@man.net

    Telephone: (204) 228-3445 Fax: (800) 442-8850

    Peacemaking is:

    1. Foundational - a central part of the gospel

    a. His position and title- functionality

    b. Jesus' saving action towards us individually

    c. Jesus' provision and charge socially

    2. Preparatory -

    a. For growth

    b. For Spiritual warfare

    c. For blessing

    3. Universal -

    a. The untroubled brother has responsibility for peacemaking Matt 18:15

    b. Care for one another -in the fellowship of the Spirit.. looking to the interests of others- Ph 2:1-4

    Peace Making Questions :

    1. Does lack of peacemaking have consequences?

    a. Judgement

    b. Ruin

    2. How does the peace increase with no end?

    a. Manufacturing

    b. Preserving

    3. What is peace making ?

    a. Reasoning process

    b. Pursuit or undertaking of the church

    c. Mutual enterprise

    . Are there techniques to dispute resolution?

    a. Negotiation

    i. Best answer for the church

    ii. Not just for disputes but for any issues

    . Mediation

    i. Requires resources in the church

    c. Arbitration

    i. One wise man

    d. Adjudication

    i. Structure is required

    5. Does any of this matter?

    a. It is to our shame if there is not at least one wise man amongst us to deal with disputes 1 Cor 6:1-5

    b. Time and money are important to the church

    6. What would I learn in a workshop?

    a. The art and discipline of negotiation

    i. Principles not positions

    ii. Listening more than talking

    iii. Disputes and issue identification

    iv. Options and creativity

    b. How to select and train mediation resources

    i. Requirements

    ii. Functions

    iii. Helpful hints



    1999 ANNUAL CHURCH & THE LAW SEMINAR

    The Y2K Problem for Charities:

    Avoiding Legal Liability

    Wednesday February 3rd, 1999


    by Terrance S. Carter, B.A., LL.B.©

    Wardlaw, Mullin, Carter & Thwaites

    Barristers, Solicitors & Trade-Mark Agents

    235 Broadway Avenue

    Orangeville, Ontario, L9W 2Z5

    Telephone: (519) 941-1760 Fax: (519) 941-3688

    E-Mail: tcarter@wardlaw.on.ca

    Web Site: www.wardlaw.on.ca


    A. OVERVIEW

    1. What are the Basic Y2K Issues?



    2. How the Y2K Problem May Impact Charities?

    3. The Broader Implications of the Y2K Problem for Charities

    4. What is the Exposure to Legal Liability from Y2K?

    5. Limitations on Legal Remedies Available for Y2K Problems

    6. Reducing Exposure to Legal Liabilities

    7. Web Resource Materials on Y2K issues

    B. WHAT ARE THE BASIC Y2K ISSUES?


    1. ADOPT A CAUTIOUS APPROACH



    2. WHAT IS THE Y2K PROBLEM OR "MILLENNIUM BUG"?



    3. WHAT DOES Y2K COMPLIANCE MEAN?

  • A single definition of Y2K Compliance does not exist

  • Compliance should include accurate and timely processing of date data using both single century and multi century formulas

  • Compliance should include years 1999, 2000 and leap year calculations and recognition

  • Compliance should include date and data communication and transfer capability

  • Compliance should include the absence of malfunctions, logical or mathematical inconsistencies, or operational interruptions due to any data

    C. HOW THE Y2K PROBLEM MAY IMPACT CHARITIES

    1. COMPLIANCE DEFICIENCIES

  • Failure to maintain records for Revenue Canada under the Income Tax Act

  • Failure to maintain accounting records for the Public Guardian and Trustee of Ontario under the Charities Accounting Act (Ontario)

  • Failure to maintain donor lists

  • Inability to produce charitable receipts to donors

  • Inability to maintain financial statements for audit purposes

  • Failure to maintain records of charitable trust funds

  • Failure to maintain investment records for surplus monies and charitable trust funds

  • Failure to maintain records involving international charitable activities through third parties, ie, agents, co-joint venture participants, partners or international projects

    2. HARDWARE DEFICIENCIES

  • Computers have internal clocks that record the time and date

  • Both older models and some newer model computers still record the years with two digits

  • Some computers can be corrected by a change to the basic input/output system (BIOS)

  • Some computers may be too old to be fixed and will need to be replaced

    3. SOFTWARE DEFICIENCIES

  • Many computer software may not work properly after the Year 2000

  • Vendors should be contacted to see if the software program can be updated to correct Y2K deficiencies before the Year 2000

  • "Detonation method" of testing for Y2K compliance by setting the computers clock to January 1st, 2000 might result in software programs shutting down, software licenses expiring, and date reminders disappearing

  • Accounts payable/receivable and payroll software may not properly work

  • Records retention and retrieval system software may not properly work

    4. DATA STORAGE DEFICIENCIES

  • Data storage using a two digit format will not work properly after the Year 2000

  • Software is generally available to update data handling programs but is not fool proof

    5. TELECOMMUNICATION DEFICIENCIES

  • Telephone switching equipment and voice mail may not work properly after the Year 2000

  • Need to check with manufacturer about the Y2K compliance of equipment

    6. ENVIRONMENTAL SYSTEM DEFICIENCIES

  • Vaults, security and safety systems, sprinkler systems, HVAC, lighting and elevators may not properly function after the Year 2000

    D. THE BROADER IMPLICATIONS OF THE Y2K

    PROBLEM FOR CHARITIES

    [Excerpted in part (with permission) and modified as necessary from the Canadian Bar Association in "Countdown To 2000 - The Legal Issues"]

    1. OPERATIONAL ISSUES FOR CHARITIES

  • Y2K compliance by third parties

    - consider what steps should be taken to determine the Y2K compliance status of third parties, such as suppliers or other charities involved in joint projects

  • Y2K representations and commitment to third parties

    - consider what Y2K representations and commitments, if any, should be provided to third parties or to donors about charitable activities

  • Disclosure obligations and financial statements

    - consider what disclosure of Y2K compliance, if any, should be made in the financial statements of the charity

  • Insurance coverage

    - consider the extent to which Y2K risks can be insured under an existing policy, if at all, and what steps should be taken to protect against or extend coverage

  • Risk management

    - consider whether steps should be taken to appoint an appropriate Y2K project management team to address the risks

  • Staffing and personal

    - consider the implications of the Y2K Problem on staffing and labour relations

  • Expert assistance

    - consider whether to seek advice from outside consultants and advisors

  • Delegation of the Y2K duties

    - consider to what extent the board of director's responsibility to deal with Y2K Problems can be delegated to a committee of the board or to outside advisors

  • Protection of privilege and confidentiality

    - consider what steps should be taken to ensure that the confidentiality and privilege of Y2K information is preserved

    - it may be advisable to use legal counsel to protect Y2K reports with a solicitor client privilege

    2. CONTRACTUAL RIGHTS AND OBLIGATIONS

  • Who owns the affected software?

    - consider whether the charity owns the software it uses or has licences for

  • Access to software source codes

    - consider who can modify a source code for customized software

  • Is software warranted to be Y2K compliant?

    - consider whether existing software licence agreement, maintenance support agreements and outsource agreements contain a warranty stating that the software is Y2K compliant or, if not, will be modified as necessary

  • Does the charity have contractual rights to modify software itself?

    - for licensed software, consider whether the software license precludes modifications without the prior consent of the software vendor

  • Is software vendor offering assistance?

    - consider whether the software vendor is offering assistance to make the software Y2K compliant and what warranties are being offered in this regard

  • Insurance contracts

    - consider whether a charities insurance may cover the cost of determining a major Y2K Problem under an existing insurance policy

  • Protection of outstanding loans

    - if the charity has loaned money then consider how it can protect its rights, and security if the borrower is likely to face significant risks associated with Y2K

    4. MAINTENANCE OF RELIABLE RECORDS FOR EVIDENTIARY PURPOSES

  • Will a Y2K Problem compromise the integrity of the records of a charity to an extent that it will render those records inadmissable in evidence in future litigation?

  • Charities should consider the extent to which an organization's inability to defend against or prosecute civil claims may occur because of a lack of a reliable evidentiary source

    E. WHAT IS THE EXPOSURE TO LEGAL LIABILITY FROM Y2K?

    [Excerpted in part (with permission) and modified from the Canadian Bar Association in its

    " Countdown To 2000-The Legal Issues"]

    1. STATUTORY SOURCE OF LIABILITY

  • Consider the statutory requirements that may be breached by lack of Y2K compliance

  • Income Tax Act and electronic record keeping requirements

  • Income Tax Act and requirements in issuance of charitable donation receipts and records

  • Charities Accounting Act (Ontario) and maintenance of accounting records for charities in Ontario

    2. PRIVATE ORGANIZATIONAL LIABILITY

  • Consider whether charities are subject to organizational obligations and duties as members of a national or international association that may be impacted by Y2K non-compliance

  • ie, failure to produce regular financial statements and reporting requirements to a national or international association

    3. CONTRACTUAL LIABILITY

  • Consider what contractual obligations may be affected by Y2K Problems

    - - i.e., direct or implied contracts to provide goods or services, technology, or equipment

  • Charities should identify the specific contracts and issues that may result in liability

    4. INTELLECTUAL PROPERTY LIABILITY

  • Consider whether remedial action undertaken to achieve Y2K compliance may infringe, breach, contravene or misappropriate intellectual property rights of others

    - ie, the Copyright Act will generally require the consent of software owners

    5. CONFIDENTIALITY LIABILITY

  • Consider whether technology and software data that is subject to confidentiality obligations will be impacted by Y2K Problems or Y2K Corrections

  • Consider whether the disclosure of, or failure to adequately protect information constitutes a breach of privacy rights, ie, failure to protect donor lists

    6. DIRECTOR AND OFFICER'S LIABILITY

  • Directors and officers may be exposed to personal liability for failure to exercise due diligence in undertaking remedial steps to avoid Y2K Problems

  • Directors and officers may be accountable to their corporate members, Revenue Canada, and to the Public Guardian and Trustee of Ontario for breach of fiduciary duties of directors in their roles as "quasi trustees"

  • Directors and officers may be exposed to breach of trust for improper investment of charitable funds if the income or the investment is lost through Y2K Problems

    7. TORT LIABILITY (ie, Civil Wrongs)

  • Negligence claims may result from damages caused by Y2K problems, ie, damages that were foreseeable

  • Claims based on negligent misrepresentation may be brought against manufacturers of hardware and software as well as service providers for misstatements about Y2K compliance

  • Umbrella organizations may be liable for failure to warm member charities about potential Y2K Problems based on detrimental relevance

    8. PUBLIC POLICY AND GOVERNMENT LIABILITY

  • Municipal, provincial and federal governments may face liability as a result of their public duty to promote and protect the public interest arising from Y2K Problems

    - infrastructure systems such as transportation, telecommunications, utilities, etc.

    - government services to individual clients, such as income distribution, licensing, etc.

    - regulatory obligations, such as audits, inspections, commission, etc.







    F. LIMITATIONS ON LEGAL REMEDIES AVAILABLE FOR Y2K PROBLEMS

    [Excerpted in part (with permission) and modified as necessary from the Canadian Bar Association in its " Countdown To 2000-The Legal Issues" ]

    1. ARE LEGAL REMEDIES PRACTICAL?

  • Determine if a legal action claim will be sufficient to protect an injured party

  • Serious consideration must be given to whether defendants to an action will be capable of paying damages and whether the defendants will even exist in the future

  • Legal remedies may not always be practical

    2. RESTRICTION ON DAMAGES

  • Do existing contracts contain restrictions on the amount of damages that can be received for losses caused by Y2K Problems?

    3. REMEDIES OTHER THAN DAMAGES

  • If damages are not an appropriate remedy, what other options are available to an injured party?

  • A party may require immediate relief rather than waiting for prolonged litigation

  • Does the injured party have the right to compel a potential defendant to fix Y2K Problems, ie, through an injunction

    4. MITIGATION OF DAMAGES

  • Does an injured party have an obligation to mitigate against damages from Y2K Problems?

    5. DISCLOSURE OF Y2K PROBLEM

  • Must a charity discloses its knowledge of a Y2K Problem to an opposite party when the Y2K problem may impact the other party?

    6. APPLICABLE LIMITATION PERIOD

  • Do limitation periods and/or other considerations restrict how or by when a legal action can be commenced?

    7. ARE THERE LIMITATIONS ON LEGAL LIABILITY

  • Contracts may contain specific provisions limiting liability and establishing conditions that must be met before liability can be found

  • Contracts may also contain certain time limitations in its representations or warranties

  • Contracts may also contain waivers and estoppel that preclude any liability claims

    G. REDUCING EXPOSURE TO LEGAL LIABILITIES


    3. MINIMUM STEPS THAT SHOULD BE TAKEN

  • Appoint someone in the charity to take charge of Y2K compliance

  • List all hardware, software and automated/electronic equipment used in operations

  • Assess compliance of equipment and systems and get help from a consultant

  • Retain qualified consultants or advisors as necessary

  • Identify most critical functions in order to prioritize and budget for action

  • Repair, upgrade and change systems and procedures according to priorities

  • Require information from third party providers about their system compliance through written confirmation Y2K compliance letters and checklists as necessary

  • Test thoroughly for compliance with respect to all Y2K issues

  • Maintain separate electronic or paper backup of records, data basis and key dates

  • Develop a continency plan for the most critical functions of a charity

  • Review insurance contracts, particularly liability coverage, to see if there is any protection available for insurance under insurance coverage

  • Review the fine print in all contracts to determine exposure to Y2K liability and possible renegotiate contracts if necessary

  • Maintain documentation that demonstrate that "reasonable care" and "due diligence" was taken by the charity to protect its assets and to continue to provide required services

  • Avoid potentially incriminating correspondence about Y2K Problems, including e-mail

  • Ensure that employees are informed of both Y2K Problems and what remedial steps are being taken to deal with the problem

  • Ensure a consistent approach is taken to deal with the Y2K Problem and do not panic

    2. WHAT DIRECTORS AND OFFICERS CAN DO TO PROTECT THEMSELVES

  • Exercise due diligence, which involves discharging duties and responsibilities with the requisite degree of care, diligence and skill required by statute and at common law in recognition of the director's fiduciary obligations akin to that of a trustee

  • Obtain indemnification from the charity or associated charities for the directors and officers with respect to potential Y2K liability

  • Obtaining liability insurance for directors and officers, if available, for Y2K liability

    3. SPECIAL PROBLEMS INVOLVING AMALGAMATIONS AND MERGERS

  • Due diligence involving mergers and/or amalgamation with other charities requires that careful consideration be given to Y2K compliance by the amalgamating charity

  • Liabilities associated with the Y2K Problem by an amalgamated charity will become the liability problem of the amalgamating charity

    4. DUE DILIGENCE REQUIRED WITH JOINT PROJECTS WITH OTHER CHARITIES

  • Y2K liability exposure of agents, co-joint venture participants, or partners of a charity will potentially impact the liability of the charity

  • Potential for liability exposure will often occur in relation to international charitable activities

  • Need to conduct due diligence compliance of Y2K Problems of other charities

    5. CONTRACTING TO CORRECT Y2K PROBLEM

  • Define Y2K services and the service provider's obligations

    - clearly describe the scope of the work and the resulting services to be provided

  • Define Y2K Compliance

    - clearly define what is meant by Y2K Compliance

  • Define project management

    - clearly describe the manner in which the Y2K project is to managed

  • Define alternative dispute resolution mechanics

    - the contract should provide for the use of alternative dispute resolution mechanism

  • Consents to modify intellectual property rights

    - consider what consents are required for the service provider to modify the software

  • Ownership of modifications

    - the contract should specify the ownership of the modifications and provide for appropriate waivers of "moral" rights

  • Protecting confidentiality

    - the contract should provide appropriate protection for confidential information

  • Representations and warranties

    - representations and warranties should be used to identify risk associated with the performance of the contract

  • Limitation of liability

    - limitations of liability should reflect the economics of allocating risks

  • Indemnification of charities

    - when should each party have an obligation to defend and indemnify the other party?

    H. WEB RESOURCE MATERIALS ON Y2K ISSUES




    Year 2000: Sharing CEO Perspectives Viewpoint

    and Executive Summary http://www.conferenceboard.ca

    http://strategis.ic.gc.ca/sos2000

    Guidance for Directors-The Millennium Bug Year 2000: Risk Management and

    http://www.cica.ca Contingency Planning

    http://strategis.ic.gc.ca/sos2000

    Guidance material from ITAC Year 2000: Technology Checklist for

    http://www.itac.ca Small Business

    http://www.cfib.ca

    January 1, 2000: Crisis or Opportunity Year 2000 legal issues

    http://www.conferenceboard.ca http://www.cba.org/abc

    DISCLAIMER: This summary of "The Y2K Problem for Charities: Avoiding Legal Liability" is distributed with the understanding that it does not constitute legal advice or establishing the solicitor/client relationship by way of any information contained herein. The contents are intended for general information purposes only and under no circumstances can be relied upon for legal decision making without first consulting with a lawyer and obtaining a written opinion concerning the specifics of your particular situation.


    Wardlaw, Mullin, Carter & Thwaites

    Barristers & Solicitors

    "Established in 1896"

    235 Broadway, P.O. Box 67, Orangeville, Ontario, L9W 2Z5

    Telephone:(519) 941-1760 Fax:(519) 941-3688

    E-Mail: tcarter@wardlaw.on.ca

    Web Site: www.wardlaw.on.ca


    tsc\seminar\ch&law99\y2k

    1999 ANNUAL CHURCH & THE LAW SEMINAR

    Web Site Issues:

    The Law and What You Need to Know


    Wednesday, February 3rd, 1999


    A. INTRODUCTION


    Despite popular belief to the contrary, the Internet is not lawless. It is governed by all of the same laws which affect us in our daily lives

    Maintaining a web site can expose a church or charity to a variety of criminal and civil sanctions if it is not careful

    The following are a number of areas of concern for church and charity web site owners

    B. COMMENTARY


    1. TERRITORIAL JURISDICTION: "WHOSE LAWS DECIDE?"

    The Internet is international in nature

    What a church or charity posts on its web site can be viewed anywhere in the world

    What a church or charity posts on its web site may expose it to the laws of potentially any other jurisdiction anywhere else in the world

    Issues of which jurisdiction is applicable is a relevant at present - the high degree of uncertainty in determining the applicable jurisdiction should lead to wariness for church and charity web site owners

    2. INTELLECTUAL PROPERTY LAWS

    All intellectual property laws are applicable to the internet including copyright and trade-mark law

    Unauthorized use of material created by someone else, may expose a church or charity to an action for copyright infringement

    Trade-mark law is applicable to web sites. If a church or charity makes use of the trade-mark of another without its' permission, whether to establish a hyperlink, a meta-tag, or to promote the services of the church or charity, then the church or charity will likely be exposed to an action for trade-mark infringement

    Obtaining necessary releases and licenses important for web site owners to reduce the chances of litigation

    3. DOMAIN NAME DIFFICULTIES

    Area of contention and uncertainty at present

    If the domain name is the trade-mark of another then a church or charity may expose itself to an action for trade-mark infringement

    At the same time, taking appropriate steps to secure its domain name is highly recommended to churches and charities

    If a church or charity fails to act, it may find itself having to purchase its domain name from someone who had the prescience to register it first

    4. CIVIL ACTIONS ON THE INTERNET

    Include defamation (libel and slander), interference with economic interests, passing-off, trade-secrets and breach of confidence, and negligence

    Defamation can occur easily on the Internet. E-mails can not be considered as privileged or private communication. Bulletin Boards and Chat Rooms allow the disenchanted to defame others

    Church and charity web site owners should carefully review anything posted to their sites, or they may find themselves publishing defamatory material

    Use of a web site to criticize the business practices, wares or services of others can lead to actions for interference with economic interests if such use leads to contracts being breached

    Passing-off can occur if a web site is used to promote goods or services in the name of another, or if the web site is designed to prosper from the goodwill of another organization or individual

    Trade-secrets can be passed easily over the internet, and breaches of confidence can easily occur through inappropriate use of e-mail, or improper security measures

    Negligence can include statements posted on a web site which are relied upon by others to their detriment, in situations where it would be expected that such reliance would occur

    Some recommendations to reduce problems

    (a) Vicarious liability of employers for actions of employees - limit employee access to the web site;

    (b) Limit access to the web site to invited guests;

    (c) Regularly monitor what is posted on your web site;

    (d) Use security measures; and

    (e) Use disclaimers;

    5. CRIMINAL ACTIONS ON THE INTERNET

    Criminal law is applicable to the internet

    Issues of jurisdiction important for criminal law - area of uncertainty

    Includes illegal speech, criminal libel and gaming

    Illegal speech involves s.319 of the Criminal Code

    Illegal speech includes: "Every one who, by communicating statements in any public place, incites hatred against any identifiable group where such incitement is likely to lead to a breach of the peace" and "every one who, by communicating statements other than in private conversation, willfully promotes hatred against any identifiable group" is guilty of an offense

    Criminal libel is defined as "a matter published, without lawful justification or excuse, that is likely to injure the reputation of any person by exposing him to hatred, contempt or ridicule, or that is designed to insult the person or, or concerning whom it is published"

    Gaming and betting is regulated through numerous applicable sections in the Criminal Code

    Generally, gaming is prohibited unless regulated by a provincial government, while section 207(4) (c) basically requires that any lottery scheme using a computer be operated by a provincial government

    Issues of jurisdiction significant when dealing with gaming

    Michigan statement on jurisdiction over internet - indicates that Michigan will try individuals under Michigan law is offer gambling over the internet to Michigan residents

    The same recommendations as outlined in the section dealing with civil law issues apply with respect to criminal law issues

    6. AREAS OF SPECIFIC CONCERN

    A number of web site design practices have recently engendered litigation in the United States, and should be avoided where possible. These include the following practices

    (a) Hyperlinking without permission to other web sites

    (b) Hyperlinking to pages on another web site, which are below the home page of the other web site

    (c) Using a meta-tag which is the trade-mark of someone else without their permission, in order to draw searches to your web site

    (d) Using 'framing' technology in order to pass of f the material of another web site, which has been hyperlinked into the frame, as your own, or in combination with your own promotions and advertisements

    (e) Spamming - mass e-mail distribution -- can lead to civil actions for damages as well as the anger of recipients

    C. CONCLUSIONS


    1. SOME EASY RULES OF THUMB



    DISCLAIMER: This summary of Web Site Issues: The Law and What You Need to Know is distributed with the understanding that it does not constitute legal advice or establishing the solicitor/client relationship by way of any information contained herein. The contents are intended for general information purposes only and under no circumstances can be relied upon for legal decision making without first consulting with a lawyer and obtaining a written opinion concerning the specifics of your particular situation.