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2004-03-25
Charities who never registered with the Provincial government:
Temporary agreement with Revenu Québec

Here is the letter that the Quebec Council of Christian Charities sent to Revenu Québec on January 12 2004:

Objet : Provincial registering

Dear Mr Aubut:

During our last telephone conversation dated January 9th, I expressed to you the desire of the Quebec Council of Christian Charities to make sure that all Christian charities in Quebec were correctly registered with both governments. When we give our training course to church treasurers and to other Christian charities, we insist that they apply the biblical principles of excellence in their ministry. This implies obedience to the laws and the rules that control our country and our province. In the book of Romans 13, the word teaches us that,

  1. Let every soul be subject to the governing authorities. For there is no authority except from God, and the authorities that exist are appointed by God.
  2. There fore whoever resists the ordinance of God and those who resist will bring judgment on themselves.
  3. For rulers are not a terror to good works, but to evil. Do you want to be unafraid of the authority? Do what is good and you will have praise from the same?
  4. For he is God's minister to you for good. But, if you do evil, be afraid; for he does not bear the sword in vain; for he is God's minister, an avenger to execute wrath on him who practices evil.
  5. Therefore you must be subject, not only because of wrath but also for conscience' sake.
  6. For because of this you also pay taxes, for they are God's ministers attending continually to this very thing.
  7. Render therefore to all their due: Taxes to whom taxes are due, customs to whom customs, fear to whom fear, honour to whom honour.

NKJV

During the last years, we noticed that certain charities, mainly churches, were registered with the federal government, filed their TP985.22 annually with the provincial government, without however, being duly registered with Le Ministère du Revenu du Québec. This may be the case for approximately 1% to 3% of the 1 500 Christian charities that we serve.

We wish to encourage those charities that are in this situation to comply with the regulations of Le Ministère du Revenu du Québec., without putting in danger the charity itself and without risking reprisals from Le Ministère du Revenu du Québec. In order to correct the situation, would you agree to register these charities if we made the following information available to you;

  1. A copy of the constitutive documents, which includes the objects of the charity;
  2. A short description of the charity's activities;
  3. A copy of the charity's last financial statement;
  4. Name and addresses of the administrators and their function within the charity;
  5. A proof that the charity is duly registered with the Canadian Revenue Agency;
  6. The designation under which the charity is registered (charitable organization, public or deprived foundation);
  7. Form TP985.5 duly completed.

Given that these situations arose from a lack of knowledge and from the confusion related to the non obligation to register before 1990, we ask that you consider our request favourably.

Thank you for the immediate attention that you will give our request.

Please accept, Mr Aubut, our best wishes.

Roger Thibault, CGA
President of the QCCC



Here is the response obtained on March 16 2004:


To the attention of Mr Roger Thibault

Subject: Registering of the charitable organizations
_____________________________________

Dear Sir:

This letter concerns your meeting with Mr. Clément Fortier last Friday, March 5th, as well as to your letter dated January 12, 2004 in connection with your suggestion for regularizing the charitable organizations statute for which you are responsible for and who would have omitted to register with our Ministry.

As we discussed previously, the charitable organizations who obtained their registration with Revenue Canada before 1989 did not have to make a request for registration with our Ministry because, at the time, the tax laws stipulated that an organization that obtained its registration with the federal government was to consider itself automatically recognized by our Ministry.

However, since 1989, the rules have changed and the organizations have to register with our government as well. According to your observations, some of them would have, for various reasons, omitted to conform to this new regulation and in order to regularize their situations, you submitted the idea that we should register them, if they give us the necessary documents.

In order to you of our ensure entire collaboration, it is our pleasure to announce to you that we have receive your request favourably, and that on reception of the required documentation, we will confirm to you by letter that they have been registered officially.

If you wish to obtain additional information on this subject, do not hesitate to communicate with the undersigned by dialling the following (418) 652-5458 or call toll free at 1-888-830-7747, then dial 5458.

Please accept, Sir, the expression of our best regards.

Denis Aubut
Direction des services à la clientèle

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