CRA considers that a B.C. community contribution company cannot qualify as an exempt NPO

The B.C. Business Corporations Act now allows for a "community contribution company" to do business and generate profits in the normal course of its commercial activities, while at the same time capping the dividends that can be paid out to shareholders. CRA considers that because the C3 is organized for profit (albeit limited profit), it will not qualify as an exempt NPO under s. 149(1)(l) – even if its articles stipulate that all its profits will be contributed to a worthy charity.

Neal Armstrong. Summary of 11 September 2014 T.I. 2014-0540031E5 under s. 149(1)(l).