Public Television Association of Quebec – Federal Court of Appeal finds that PTAQ was a conduit for a U.S. public TV station

In order for a Quebec-based corporation with educational TV objects (PTAQ) to qualify as a "charitable organization" under s. 149.1(1), it was required to itself carry on charitable activities rather than merely disbursing funds to a non-qualified done, in this case, a Vermont public TV station (VPT).  Accordingly, agreements were carefully crafted to require VPT to produce non-commercial television as agent for and at the direction of PTAQ and engage in fund-raising for PTAQ.

This structure was ignored by them.  PTAQ merely purchased programming from VPT that had been assembled without input or control by it.  Indeed, PTAQ was merely a "conduit" for VPT, i.e., VPT allocated its Canadian donors to PTAQ, PTAQ issued receipts to them, and paid the proceeds over to VPT in amounts that always matched VPT’s programming charges.

Neal Armstrong.  Summary of Public Television Association of Quebec v. M.N.R., 2015 FCA 170 under s. 149.1(1) - charitable organization.