Principal Issues: 1. Can an organization that is exempt from income tax under paragraph 149(1)(l) receive donations from its members and businesses affiliated with its members to fund a capital project? 2. Can the organization recognize the contributions from members on a "wall of honor" or through naming rights of capital assets?
Position: 1. Yes, provided that the capital project is funded with member contributions and gifts. 2. Question of fact, the amount received may be a donation or other income.
Reasons: Since an 149(1)(l) organization does not operate for profit, it funds capital projects through member contributions, gifts, grants and incidental profits. Provided a project is funded with member contributions and gifts, an increase in services to members will not indicate that income has been made available to its members.