Impact of Charitable Status changes unclear-

Revenue Canada is planning changes that could have a devastating impact on animal rescue groups, and the deadline for commenting on the proposed change is tomorrow, March31.  As stated in the proposed regulations, “Promoting the welfare of animals is only charitable when it results in a benefit to humans. Purposes that benefit animals, but not humans, are not charitable.”

What does that mean?  Does that mean that people who form a group to rescue injured or abandoned animals are not covered under Charitable Status?  Without Charitable Status, you can’t apply for grants to develop projects to fill in the gaps not covered by local, provincial, and federal funding.  And you can’t issue a tax receipt.

If you are coping with an unprecedented amount of abandoned animals being churned out by puppy mills, backyard breeders selling on Kijiji, and people forced to give up their household pets due to economic hardship, does that mean you cannot attain or retain Charitable Status if you speak out against the practice of puppy mills that are causing you to try to raise the funds in the first place?

The following was a letter sent to Revenue Canada regarding proposed changes the Charitable Organization Status March 30, 2011:

Comment:  Promotion of Animal Welfare & Charitable Registration Guidelines

It is mainly the allowance for “potential” economic harm (both “direct or indirect”) to people as a criterion for what would make animal welfare groups ineligible for charitable status that bothers me.  I will give just one example.  Puppy mills are a source of revenue for many people directly and for people and regions indirectly.

In the state of Missouri, as we have recently learned in discussions of Proposition B which wished to enact guidelines for the operation of commercial dog breeding businesses, puppy mills are a lucrative source of state-wide revenue and employment.  Opposition to Prop B was swift and vociferous, and despite being passed, it was almost immediately struck down.  Opponents of Prop B saw the efforts to regulate puppy mills, thereby improving the lives of animals in such facilities, as harming their economic health and that of the wider society.  I believe similar arguments were advanced against those who fought for the abolition of slavery.

Organizations whose main purpose is regulating and/or closing down commercial dog breeding enterprises (aka puppy mills, backyard breeders) through political or direct action would not be eligible for charitable status under your guidelines.  Organizations that care for and give shelter to abandoned, abused and unwanted dogs would be eligible.  However, too many of those abandoned, abused and unwanted dogs are the direct result of the proliferation of commercial breeding, both large and small scale, in recent years.  “Designer breeds” (“Doodles”, “Schnoodles”, “Jugs”, “Puggles”), breeds made popular by movies (Dalmations and Chihuahuas), breeds popular as “statement” dogs (guard breeds), dogs legislated against (pitbulls and dogs that look like pit bulls) – all these types of dogs are filling animal shelters because they are being bred in high volume for profit (i.e. human benefit).

So should shelters and rescue groups that are stretched to their limit physically and financially just continue to take these dogs in?  What do they do when the shelter is full and there are no more foster homes?  Euthanize healthy dogs?  Refuse to accept more?  Both these things are being done.  Why not stop the problem where it starts?  And that means taking political action to shut down irresponsible breeders, despite the economic benefit that accrues to the breeder person.

Is not stopping a problem at its source a benefit to society as a whole?  This caveat about economic hardship, both actual and potential, is a loophole that allows groups who wish  to stop degrading and abusive human action to be hampered or stopped themselves.  It allows for withholding or removing the financial support and social sanction that registered charitable status confers.

I don’t imagine, in Canada, that puppy mill operators have sufficient clout to get Canada Revenue protection.  But I do see “big agriculture” and “big pharmaceuticals” written all over this proposal.  The same arguments that I have advanced regarding puppy mills apply to factory farming and unnecessary animal laboratory testing.

Thank you for your time.
Dorothy Stewart (proud owner of a rehabilitated Poodle who spent five years as a puppy mill stud making Labradoodles)

More on the St. Thomas Dog Blog.  The link for the changes proposed by the CRA is here, and it is a formidable act to get through and understand.  The email address to comment is consultation-policy-politique@cra-arc.gc.ca.