Needs to show Public Benefit
http://www.cra-arc.gc.ca/tax/charities/policy/cps/cps-024-e.html
3.3 Proof of Public Benefit
The existence of public benefit must be demonstrated through evidence submitted by the applicant organization. It is not sufficient for an applicant to merely state that in its view a public benefit will derive from the purposes.[Footnote 57] Examiners may consider a broad range of materials filed in support of an application for registration as a charity. The nature and extent of the evidence required will largely depend on the purpose the organization is seeking to have recognized, its approach to achieving the purpose, and any limitations the organization places on the class of beneficiaries. Where the purposes are novel or there is some type of restriction on the beneficiary class, additional objective evidence may be required.
An applicant organization is well-advised to consider supporting an application with some of the following information to establish public benefit. At the same time, however, it should be mindful of the fact that the submission of such information may not always be enough to demonstrate public benefit in the circumstances:
Needs assessment studies by academics, government bodies, or non-profit organizations that document the existence of the need in the community which will benefit from the services;
Project and/or funding proposals that address how the proposed activities are best suited to meet the need and benefit the community;
Program evaluations showing that similar programs or this specific proposed program has been demonstrated to benefit the community by meeting the need effectively;
Identification of government programs addressing the community need in question along with details on how the program complements or supplements the government program;
Identification of explicit statements of government policy that may be consistent with the goals and objects of their organization;
Demonstration of existing public sources of financial support for the organization;
Identification of new or recent legislative initiatives consistent with the proposed purpose; and,
Any other types of objective material that supports the proposal.
Although legislative initiatives may be considered, the mere existence of legislation is not conclusive evidence that an organization is pursuing a public benefit in a way the law regards as charitable. According to Iacobucci, J., in Vancouver Society, the benefit must still be determined through "... analogy to cases already found to be charitable."[Footnote 58] It is not that legislation is "never relevant to the question of what is charitable." Relying on the decision in Everywoman's Health Centre, he noted that the court there " pointed to legislation in order to rebut the argument that the provision of abortions in private clinics was contrary to public policy."[Footnote 59]

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