Taxing charities, imposer les organismes de bienfaisance : harmonization and dissonance in Canadian charity law
Bibliographic record
Abstract
For many years, the determination of which organizations should qualify for the significant tax benefits accorded to "registered charities" ( "organismes de bienfaisance enregistres") under the Canadian Income Tax Act has been based, in all provinces, on the concept of charity developed by the English common law of charitable trusts. However, there are other sources of meaning for the concept of "charity" ( "bienfaisance") in Canada, including ancient, civil law sources that continue to form part of the basic law of Quebec. This study challenges the longstanding, unijural approach to the registered charity provisions on the basis of the constitutional division of powers, and the federal government's commitment to respecting bijuralism and bilingualism in its legislative texts. It explores the diverse, legal sources concerning charity and the devotion of property to the public good that form part of the law of property and civil rights in the provinces. Finally, it examines how these diverse provincial sources might affect the current approach to the registered charity provisions, and the project of ensuring that federal laws are accessible to each of Canada's Francophone civil law, Francophone common law, Anglophone civil law and Anglophone common law audiences.
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How this classification was reachedexpand
Full frame distilled prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. Learned from the 10,348 direct Codex labels and 10,348 direct Gemma labels. Candidate is the union of thresholded teacher heads; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels or direct frontier model labels.
Codex and Gemma teacher scores by category
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.001 | 0.000 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.000 | 0.001 |
| Science and technology studies | 0.003 | 0.000 |
| Scholarly communication | 0.000 | 0.001 |
| Open science | 0.000 | 0.000 |
| Research integrity | 0.000 | 0.000 |
| Insufficient payload (model declined to judge) | 0.000 | 0.000 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one teacher head, not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".