“Only in the most serious cases of non-compliance…does the CRA turn to revocation” of a charity

CRA conducted 840 audits of charities in the 2013-14 audit program, plus some additional political activities audits.  Of the 840 audits, 513 resulted in (only) "education letters,"137 in compliance agreements, 5 in "sanctions" (presumably monetary penalties), 34 in revocation notices (and 20 in voluntary revocations).  "Only in the most serious cases of non-compliance—for example, when an organization has a previous record of non-compliance, when the non-compliance has had a substantial adverse effect on others, or when an organization cannot or will not take steps to bring itself into compliance—does the CRA turn to revocation."  CRA "audit[s] all registered charities that play a role in a tax shelter gifting arrangement."

"[I]n order to demonstrate that it is carrying on its own activity, a registered charity must maintain direction and control over the use of its resources. ...  A properly structured agency or joint venture agreement can help demonstrate direction and control. Even when an agreement exists, however, the charity must ensure that it is monitored."

Neal Armstrong.  Summaries of Cathy Hawara, Director General, Charities Directorate, "The CRA Charities Directorate's Approach to Compliance", 2014 Conference Report, Canadian Tax Foundation, 37:1-10 under s. 149.1(2), s. 149.1(1) – charitable organization, charitable foundation, ineligible individual, s. 149.1(1.1), s. 188.1(9).