The Canada UNI Assn. v. M.N.R.

A-145-92

Marceau J.A.

1/12/92

Appeal from denial of charitable status-Appellant non-profit organization formed to promote Canadian unity -- Arguing charitable as purposes included advancement of education and other purposes beneficial to community -- M.N.R. holding mere provision of information not educational -- Activity must involve element of training or instruction -- Holding no legal precedent establishing promotion of national unity or personal exchanges between Canadians beneficial to community in way law deems charitable -- Appeal dismissed -- Nature of appellant's objects and intended activities virtually indistinguishable from those considered in Toronto Volgograd Committee v. M.N.R., [1988] 3 F.C. 251 (C.A.) wherein Court holding inherently political nature of organization's objects and activities precluded finding fell under third or fourth charitable heads developed under federal law -- Contrary finding herein would constitute not only evolution of concepts, but complete transformation -- Native Communications Society of B.C. v. Canada (M.N.R.), [1986] 3 F.C. 471 (C.A.) distinguished as Society's activities directed towards native persons holding special position in Canadian society.