Policy Forum: Using Dual Structures for Political Activities--Charities and Non-Profits in the Same Family of Organizations
Bibliographic record
Abstract
The rules in the Income Tax Act and in Canada Revenue Agency (CRA) policy limit the amount and type of political activity that registered charities are permitted to carry on. Since non-profits are not subject to these rules, organizations are known to use dual structures to carry on political activity. In the past few years, the CRA has audited charities for their political activities, and although the audit program is being wound down, many charities remain concerned about these audits because of the significant costs involved in defending them and the risk of losing their charitable status. This article describes how dual structures are implemented, as well as the compliance issues that need to be considered for this type of planning. The authors' comments are based primarily on experience dealing with the CRA: few government documents have been published in this area, and there is little case law. Recently, a panel of experts appointed by the minister of national revenue prepared a report for the minister with recommendations on how to clarify and potentially broaden the ability of registered charities to carry on political activity. The CRA is expected to comment on the report in the coming months. It is expected that charities will continue to use dual structures to carry on political activity for the foreseeable future, since this type of planning offers various advantages.
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How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.016 | 0.024 |
| Meta-epidemiology (narrow) | 0.001 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.001 |
| Bibliometrics | 0.001 | 0.002 |
| Science and technology studies | 0.015 | 0.009 |
| Scholarly communication | 0.017 | 0.016 |
| Open science | 0.002 | 0.005 |
| Research integrity | 0.018 | 0.009 |
| Insufficient payload (model declined to judge) | 0.041 | 0.005 |
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 source (direct Gemma or distilled Codex), 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".