Recent NEWS

May 7, 2024

The trial is finally wrapping up, with closing arguments scheduled for June 10, 2024 in Calgary Tax Court.   We are very happy with the way the trial has gone so far.   We expect to have a Tax Court decision before year end. 

November 19, 2023

We have finally had our day in Tax Court for the PGC Class Defence for COIP/RLG/MLF/PGI.   We are exceeding happy with the way things are going.  We feel we have convinced the Court of the validity of our 5 test cases' donations  Stay tuned for the verdict....

Sept 15, 2022

The CRA has been sending out Notices of Confirmation (NOC) for many different donation programs.   If you have received a NOC from CRA, and are a Member of Profitable Giving Canada, please contact [email protected] 

August 14, 2021

It is with heavy hearts that we report the passing of Bruce Allen,  at the age of 55, after a lengthy fight with cancer.  He passed peacefully, with friends and family nearby on July 28..   

Bruce was a Committee Chair and a Director of Profitable Giving Canada.  He will be sadly missed.  Bruce was kind and determined, purposeful and focused in all his dealings for PGC.  He was a gentle giant.  He spoke the truth but was  private, confidential, a good listener, yet well able to share his opinion

Thank you, Bruce, for sharing your life with us. Rest in Peace our brother!

January 26, 2021

If you participated in the COIP, RLG, MLF, or PGI donation programs, you should now have received (or will very soon receive) a letter from the Canada Revenue Agency providing you with an Agreement to be Bound by the Tax Court litigation of our five test cases.   

The “Lead Cases” referred to in CRA's letter are the five test cases of our Class Defence, and their litigation is funded by and on behalf of our Members to defend against the CRA’s refusal of their tax credits.

All members of the Class Defence will soon have the ONLY means to officially, formally, and legally bind themselves to the results of the Tax Court litigation currently being undertaken by our five test cases.

It is extremely important for our Members to make the appropriate decision when dealing with the CRA letter.  Please login to the Members Section and read the information in Section 10.7

It is also still not too late for Non-Members to join our cause and  potentially reap the benefit of the five test cases in our Class Defence. If you wish to join our cause, please just Contact Us. and we can assist you.


January 27, 2020

Below is another update from Ross Morrision regarding his appeal to Federal Court for the CHT and CGI donation programs.

The above-captioned appeals to the Federal Court of Appeal from the Decision of the Tax Court of Canada have now been scheduled for hearing.
The appeals will be heard by the Federal Court of Appeal on Tuesday, March 3, 2020 commencing at 9:30 a.m. at 180 Queen St. W., 7th Floor, Toronto.
The Appeal Books (13 volumes) and Memoranda of Fact and Law have been filed with the Court, and the preparation of oral argument for the hearing of these appeals has begun in earnest.
I shall be grateful for any additional financial contributions which you may make to defray the substantial cost of proceeding with these appeals. In the meantime I shall keep you advised.
Thank you.
V. Ross Morrison      

Direct: 416.368.5972
Main: 416.368.0600

Please note that this is for information only.  The CHT and CGI programs are not ones that PGC is involved with. It is completely independent from our Class Defence for the COIP, RLG, MLF, and PGI programs.  


October 9, 2019

For those of you who participated the CHT or GCI donation programs, we have just received an update to our message posted the past Feb 10 below.   The update from Ross Morrison reads as follows:
A brief of summary of the status of the above-captioned appeals is as follows.
In December, 2018 Notices of Appeal from the Judgment of the Tax Court of Canada were filed with the Federal Court of Appeal.  Thereafter the Appeal Books and Memoranda of Fact and Law were filed with the Federal Court of Appeal by legal counsel for both parties. The appeals have therefore been perfected.
We are waiting to hear from the Federal Court of Appeal as to a date or dates for the hearing of the appeals, possibly in January of 2020.  In the meantime I am hopeful that you and others who have participated in the CHT and CGI Programs will be making a financial contribution to defray the significant costs of proceeding with these appeals.
Cheques should be made payable to my law firm, Morrison Brown Sosnovitch LLP, in trust at the address which appears below.
I shall keep you advised as to the status of these appeals as they move forward to a full hearing before the Federal Court of Appeal.
Ross Morrison
Please note that this in not a PGC initiative.   We are simply making participants in the CHT and CGI program aware of the appeals that are being undertaken. 

August 7, 2019

If you participated in the Global Learning Giving Initiative (GLGI) , then this message is for you.   Things are really heating up at CRA and with the Tax Court regarding the GLGI program..  The CRA is being urged to issue Notices of Confirmation to the thousands of partcipants in this program.  If that happens, then the donor will have no choice but to file an appeal to the Tax Court or pay back the CRA all the tax in dispute. 
The purpose of this message is to make you aware that there is a Law Firm in Toronto, Milot Law,  prepared to defend donors who participated in the GLGI Program. They are not connected in any way to the promoter, but are trying to litigate a number of "Test Cases" on a cost effective basis , funded by a larger group. This is not a PGC initiative, but rather a Milot Law initiative.    It is our understanding that they would try to adduce better overall evidence and more comprehensive valuation reports.   If you would like to see more information on the Milot Law GLGI initiative, and how you could benefit from joining with them, please click HERE.
Please note that this has nothing to do with the current PGC Class Defence and is completely independent from what we are doing for different programs.  Also, PGC cannot offer any opinion on the chances of success or failure of the Milot Law initiative, however, analyzing one loss can often provide a road map for a new and different approach with better results.

July 30, 1019

We are pleased to annouce that Bruce D Allen has been appointed ot the Board of Directors of Profitable Giving Canada.  Bruce, who lives in Calgary,  has been serving as Chairman of the PGC Disiplinary Committee for many years now and has also provided services to us in other important areas.  You can see Bruce's profile in the Committees Section of our website.   Welcome Bruce, we look forward to your continuing support for the PGC mandate and objectives. 


February 10,2019

If you participated in the Canadian Gifts Initiative (CGI) or the Canadian Humanitarian Trust (CHT) programs, this is a very important message for you.    We reported earlier that the Tax Court finally issued a decision on several of the appeals before it, and it ended up being only a partial victory for one of the appellants, Mr Ross Morrison.    The CRA had denied 100% of all donations, however, the Tax Court Judge allowed the cash portion of his donation and denied the "in kind" donation of pharmaceuticals. 
Ross Morrison is a Toronto litigation lawyer, Partner at Morrison, Brown, Sosnovitch LLP.  He has decided to Appeal the Tax Court decision to the Federal Court of Appeal and has done so.   His primary argument is that the  Tax Court Judge erred regarding the evidence surrounding the fair market value of his pharmaceutical donation.   Read More

December 1, 2018

Crowd Funding is one of the most effective and simplest ways for individuals and organizations to raise funds for their personal or business needs.   We hear of it all the time on the news.   Funds raised can be used for just about any purpose. But what if you could not only give to a cause of your choice such as PGC, but make a profit at the same time?   Another form of Profitable Giving!   Watch Video

November 22, 2018

There has been a decision rendered by the Tax Court of Canada on the CGI and CHT programs for tax years 2003, 2004, and 2005..  The trial  occured in the late spring of this year with several appelants, however, the week before the trial began, Mr Stephen Rosen (the creator of these programs) and Mr Eric Miller (the head marketer)  withdrew their appeals.  This left only two appelants, Mr Ross Morrison and Mr Dieter Eisbrenner.   The appeals were heard on common evidence.  The Tax Court decision by Justice JR Owen was a partial victory for Mr Morrison in that his cash donation to charity was allowed, however, his larger gift in kind was disallowed.  You can see the full decision HERE.   Technically , this decsion applies only to these appelants.  It is unclear how CRA will treat the balance of CGI and CHT participants with outstanding objections. 

October 25, 2018

During the September annual meeting of the PGC Faculty Members,  John Remesz from Kelowna BC was elected to the PGC Board of Directors.   John has been serving us well as a volunteer for some years now and also as the Chairman of the Peer Review Committee.  Welcome John, to the PGC Board  

July 10, 2018

For those of you who participated in the Canadian Humanitarian Trust (CHT) donation program, we understand that  lead cases were heard in Tax Court from April 17 to May 16, 2018.   The trial has now concluded.   As is normally expected, the Judge reserved his decision and will deliver it later.   We have seen this process take anywhere from 3 months to over a year.   We will post another update once we hear of the decision. 

Unless you signed an agreement to be bound by this decision,  it is not certain that your particular case will be determined by this decision.  CRA may appeal to the Federal Court if they lose, and so may the appelants if they lose.   Tax Court does not generally set precidence.    It could still be a long time before your evenutal and final tax position is determined.  


June 7, 2018

We are extremely pleased to announce an addition to our legal team for our current Class Defence.   Now that we are approaching the litigation phase of the process, we are pleased to announce that Mr Joel Scheuerman, BA, MA,  LLB, BCL, and tax partner at BCF Buisness law will take over this function from Nicolas Cloutier.  You can see his profile at the BCF Website,   Welcome Joel!

November 2, 2017

For those of you who participated in the Canadian Humanitarian Trust (CHT) or Canadian Gift Initiative  (GCI) donation programs, you may be aware that the Tax Court date for these programs was delayed from February 2017 and is now scheduled for April 2018.   If you still have tax in dispute for either of these programs, and have not signed a waiver or settled with CRA,  Stephen Rosen would like to hear from you.  You can get more Details Here.

June 26, 2017

We have had numerous of our Members ask us about the Synergy Program and their dispute with the CRA.  Synergy was not a tax shelter nor a donation program so it doesn't really fall within the jurisdiction of Profitalble Giving Canada.   However, if you  wish to join their group appealing the CRA reassessments, you can get more information at Synergy Dispute

May 30, 2017

If you participated in the Parklane Donations for Canada donation program, you may be entitled to a share from the recent Class Action law suit.   You can get more details HERE.   It applies to donors who partcipated between 2005 and 2009 only. 

Feb 1, 2017

The CRA has finally started their campaign to collect on tax in dispute from the COIP program.   Many taxpayers are receiving the CRA settlement offer and being asked to sign a waiver.   It is a very poor offer.   We stongly recommend that you DO NOT SIGN the waiver.  If you do so, you are giving up all of your taxpayer rights to appeal the CRA's decision.   Instead,  we suggest you join our Class Defence and let us protect you from the CRA collections   We have the best legal team available to do just that.   For more information, please come to one of our FREE SEMINARS,  or contact us a 519-964-2780 or [email protected]

We are here to help you!

Dec 6, 2016

We are extremely pleased and excited to announce the finalization of our Legal Team representing our Members who have joined our Class Defence.  McCarthy Tétrault is one of the largest law firms in Canada and Nicolas Cloutier is the Head of the Tax Group in Montreal.    Nicolas and his team are hardworking, extremely effective, and down to earth tax litigators with a proven record of results.  Nicolas has been named one of Canada's Best Lawyers in several different forums lately.   Along with the expertise we have on our Legal Affairs Committed,  we think we have the absolute best team available to represent you.  To quote Mr Cloutier, "We will team up,  work hard, turn the tide, and prevail."   We certainly do expect to prevail.  If you have not joined our Class Defence for the programs we are defending,  now is the time to join.   The CRA is starting to get aggressive, and they will  only listen to the Courts now.  

Nov 8, 2016

As many taxpayers are finding out,  the CRA is issuing Notices of Confirmation for reassessments coming from the GLGI program.   After the results of the Mariano case in Tax Court, most taxpayers don't realize they still have a choice when dealing with the CRA Confirmations.   Read More....

Nov 3, 2016
We are very pleased to announce that Ed Gilmore of Gilmore and Associates has just recently given his full endorsement of the PGC Class Defence initiative.   Ed has also given his endorsement of the Justice Pharma program for the settlement of donation debts in a compliant manner.   Ed has been very active in dealing with many clients and successfully assisting them with the CRA issues they face.   As a former CRA officer and now an Income Tax Consultant,  we are very pleased to see Ed recommending us and our services to his clients.
Click here to see the Full Endorsement 
Nov 2, 2016
Due to a large number of requests, we have extended the date for Member free registration for our Class Defence.   The new deadline is Nov 15, 2016.   Any PGC Member wishing to subscribe to our Class Defence can do so for free prior to that date.   Just login to the Members Section , go to Section 10.1 and follow the instructions.   After Nov 15, 2016,  there will be a one time $100 fee for subscribing.
Oct 16, 2016
We are seeing the start of a massive campaign from CRA to issue Notices of Confirmation.   It appears they have decided now is the time to collect on those reassessments for a variety of programs that were popular in the last decade or two.  Many many taxpayers will be facing great hardship as the CRA is relentless in their efforts.   We have written about the various programs that are undergoing this attack and the options that taxpayers have to fight back.   It is contained in our Members Section 5.2.
Sept 10, 2016
It is with sad hearts that we announce the passing of Robert Allen,  Income Tax Consultant, PGC Faculty Member,  Chair of our Peer Review Committee, and a member of our Board of Directors.    Bob passed away Sept 8, 2016 after suffering a stroke a few days earlier.   Bob will be truly missed, as he was one of the strongest advocates for protecting the rights of taxpayers and individuals who participated in Profitable Giving.   Bob was a true Canadian Hero.  Expressions of sympathy may be made in Bob's name to the Hospice House in Vernon, BC.
Aug 19, 2016
For those of you who participated in the COIP  (Canadian Organization for International Philanthropy) donation program,  the CRA will soon be contacting you.   We have learned from CRA that 4 appeals that were before the Tax Court have recently been dropped by the appellants.  The CRA was waiting for the outcome of those appeals before they proceeded with any other actions for the rest of the participants.   Now, the CRA is feeling victory and a senior officer in the Aggressive Tax Division has confirmed that they will start issuing settlement offers this September.  It may take several months to get to everybody. They feel strongly that no valid donation was made and therefore are not backing off on their reassessments.  They will, however, offer a few years of interest relief on the tax in dispute.   If you participated in the COIP program,  you still have time to join our Class Defence before CRA gives you a deadline.   We believe that a valid donation was in fact made, and our Class Defence intends to prove it in Tax Court for those of you who join.   Please don't wait till it is too late!
Jun 22, 2016
Revised June 30
In addition to our May 21 post regarding the CHT program,  we have learned from the owner,  Steven Rosen that he is continuing his appeal to Tax Court.  A Court date has been set for February 2017 and this will be heard the same time as the Morrison initiative.  It is likely that Rosen and Morrison will have similar arguments and we are continuing discussions with him to see if there is anywhere we can help.  Stay tuned.....

May 21, 2016

For those of you who participated in the Canadian Humanitarian Trust (CHT) or the Canadian Gift Initiative (CGI) registered gifting arrangements, we would like to inform you about new initiative to defend your tax credits against the CRA reassessments.   A group is forming under the leadership of Toronto Lawyer Ross Morrison, who has sent out an email explaining the initiative and details.  You can see the email HERE.

April 21, 2016

Many taxpayers are presently receiving letters from CRA regarding the 2007 Universal Donation Program (UDP).    This program was also known as the Universal Healthcare Trust (UHT) program.    This program was created and ran by David Singh,  who is not longer supporting or responding to  his clients/donors.   This leaves many taxpayers in a difficult situation, not knowing how to respond to the current CRA settlement offer letter. Milot Law of Toronto Ontario is providing select legal services to some donors who wish to continue the fight with CRA.   Do not contact them expecting free advice,  but call them if you are seriously interested in joining their group.

Mar 19, 2016

We finally received a response from the Minister of National Revenue (MNR) to our letters of November 10, 2015 and January 15, 2016.regarding the CRA GTS Policy.   The response from the MNR is very disappointing.   She has basically reiterated the CRA position on gifting arrangements, restated facts that are now known to be untrue, and not answered our questions regarding the Federal Court decisions.  The MNR states that the CRA will be advising  affected taxpayers directly of the impact of these Federal Court decisions. We know of no taxpayer who has received such direct notification.   If you participated in a Gifting Arrangement in 2012 and later,  and you have received a letter from CRA advising of the impact of the Federal Court cases on the CRA GTS policy,  we would greatly appreciate it if you would contact us.  We have posted all letters in the Advocacy Section of our website.

Mar 18, 2016

We have several Members inquiring about a recent message sent from GLGI regarding CRA collections and a company called Tax Solutions Canada.    PGC does not offer tax advice on this situation, each GLGI participant must make their own decisions.   We can say, however, that GLGI donors likely have few options left after the GLGI loss in Tax Court last fall that we wrote about in this column.  Tax Solutions Canada appears to be a legitimate organization, offering services that may be helpful for those taxpayers assessed penalties and huge interest bills.   To date, however, we have not seen any penalties assessed yet for GLGI participants, but that does not mean there are not any specific cases.  We understand that James Bell actually is a former CRA agent who is very familiar with the GLGI program.  

On another front,  we understand the Merchant Law Class Action on behalf of GLGI donors has just now been registered in Saskatchewan   provincial court.   The action names numerous defendants including GLGI, the CRA, and many firms who opined on or otherwise promoted the GLGI program.  For those donors who wish to continue the fight,  this action is most likely the only option left.


Feb 21, 2016

CRA is at it again !  Now that the Federal Court has forced them to issue the assessments from 2012, 2013 and 2014 that they were withholding, they are doing so in a very confusing and sometimes contradictory manner for many taxpayers.  We have written about it on our BLOG, however,  the CRA Gobbledegook often needs a translator so you know what they're doing and what you need to do too.  To help you,  we've scheduled another series of Free Seminars and would love to see you attend.   If it's just all too confusing for you, and you would like to have someone just do everything for you, we recommend you contact   Robert Allen.

Feb 19, 2016

We have previously issued an Alert over the tax advice being offered by the FAST Track group out of Alberta.  PGC is of the opinion FAST has not provided the proper support and advice to their many clients who participated in one of the Pharma Tax Shelter programs.   It now appears, that FAST is also providing other advice that some of their clients do not appreciate.   There is a Group Forming out west to discuss their options.  PGC offers no opinion on this group, we only offer the opinion on the FAST tax advice.


Feb 2, 2016

We have developed a new webpage for our Free Seminars.   The webpage makes it easier to see the seminars and register for a "waiting list" if we don't have a seminar in your area right now.   It is our intention to schedule a new series of seminars across Canada soon and we would appreciate your input as to where we should come.  Please look at our new Seminars Page.


As we reported in our Jan 14, 2016 News Item, CRA is now issuing tax assessments for 2012, 2013, and 2014 taxpayer returns that were previously being held.   The results of these assessments can be very confusing and are different for different people.   Some taxpayers are getting refunds for some years while others are not.   We have written about this in our BLOG based on what CRA reported to us.  However, we have seen some very difficult and confusing language coming from CRA with the assessments being issued.   If you think CRA has denied your donation tax credits,  it is very important to file your Notice of Objection within the 90 days objection period.  We have complete instructions in the Members Section of our website.   In addition,  Robert Allen has also written an article in the Member Articles section which should help provide you with information.   You may also use the Contact Us page, if you need any assistance understanding the CRA gobbledegook.   

JAN 22, 2016

The Federal Court of Appeal has issued a decision on the  GLGI Class Action appeal we referred to in our News Item of Oct 18, 2015 below.   The FCA allowed the appeal with permission to amend the pleadings.  In effect, this means that particular Class Action cannot proceed the way it was plead, however, if it were amended, it might be allowed to proceed.   It is important to point out that this is not the Merchant Law Class Action initiative we referred to in our July 17, 2015 and Dec 11, 2015  News Items.  Merchant Law believes this FCA decision will help them draft their case.   PGC offers no opinion on the strength of any of the GLGI initiatives.   You can see the FCA Decision HERE.

JAN 14, 2016

We have confirmed with CRA that they are now recognizing the McNally Court decision and are processing all tax returns that were previously being held.   Each taxpayer has a unique circumstance,  which means some refunds are being issues while others are not.   We have written more about this on our BLOG.

JAN 9, 2016

We are starting to hear reports that 2012 and 2013 tax returns that were previously being withheld by CRA.are now being processed.   Some taxpayers are reporting to us that they have received the full refund anticipated as a result of their tax shelter participation.    CRA has not announced that they have abandoned their GTS policy, however,  the McNally Federal Court decision and appeal really leaves them no choice.   We are attempting to follow up and find out for sure.   If any of you have received your 2012 or 2013 tax assessments with full refund as expected from your tax shelter donations, we would appreciate hearing from you.   Please email [email protected]    

DEC 19, 2015

Robert Allen, Income Tax Consultant and PGC Director, has written a very interesting article on Taxpayer Rights and the Collection practices of the CRA.   It seems CRA is treating Taxpayers differently and in many cases not even following their own protocols.  Bob also gives advice on what to do if you get a telephone call from someone who claims to call from CRA.   The article is in Members Section 5.5 


DEC 14, 2015

In addition to our Dec 7, 2015 post regarding the Universal Barter Group (UBG) program,  we are passing along information regarding a conference call from Milot Law that will explain the status of the Appeals on this program.   If you were a participant in the UBG program, you may want to learn how Milot Law can assist you in disputing the CRA reassessments.   They will hold a telephone conference on Dec 17, 2015 at 7 pm (Eastern Standard time) and on December 23, 2015 at 7 pm (Eastern Standard time).  The instructions to call their office are as follows:

(1)    If you live outside of Toronto, please call 888-345-2160 and input the access code, 6011002, following the prompt.

(2)    If you live within the Toronto area, please call 416-620-2160 and input the access code, 6011002, following the prompt.

During the telephone conference, Mr. Milot will answer your questions and help you make an informed decision as to how you should deal with the CRA reassessment of your UBG donation.  


DEC 11, 2015

As we reported in our Oct 23 news item,  several donors who participated in the Global Learning Giving Initiative  (GLGI) program for 2004 and 2005 have lost their case in Tax Court.  The appeal period has now passed and the decision was not appealed by those donors or GLGI.   It is not clear what the CRA will be doing as a result of this decision, however, it is most likely they will apply this decision to all donors for those years, confirm the reassessments, and start collections for the tax owing.  It is also possible that CRA might apply this decision to other tax years as well, considering the program did not change substantially from year to year.  If you were a participant, and receive a notice of confirmation of your reassessment  (ie your objection is rejected by CRA Appeals),  the next and only step you have available is to appeal yourself to Tax Court.  That is not likely the best decision, considering the Tax Court decision just rendered.  Otherwise, you will need to make arrangements to pay the CRA what they say is owing.

For those donors who wish to continue the fight but do not have the resources or competence to fight in Tax Court,  there is one other alternative we are aware of.   A fairly large group of GLGI donors have joined a Class Action law suit that is planned against CRA,  claiming damages for the way they were treated by CRA for participating in the GLGI program.   PGC does not offer an opinion on the validity of this action, or it's chances of success, however, we want to make donors aware of the option they have.   You can get more information at    


DEC 7, 2015

For those of you who participated in David Singh's  Universal Barter Group (UBG) tax shelter,  the CRA is asking donors if they wish to be bound by several individual cases that are presently before the Tax Court.   Most of these cases are being argued by Milot Law of Toronto, who is attempting to put together a funding group in order to be able to continue.   If you are interested, you can get information or contact them through their website    If the Milot cases do not get funded,  UBG donors who wish to continue the fight with CRA will have to go it alone.  PGC does not offer an opinion on the validity of the UBG program, we are just providing information so that UBG donors know their options.   David Singh also promoted a program called Universal Healthcare Trust  (UHT).   We have no news on this program.  The UHT reassessments are presently held in abeyance by CRA.


NOV 10, 2015

The CRA appeal of the McNally decision has been dismissed by the Court of Appeal.   The decision was unanimous from the 3 Judges hearing the case.    Of particular interest is the fact that the Court again pronounced that the CRA's GTS Policy of delaying tax returns in order to deter taxpayers was not a valid policy under the law.  Surely now, the CRA will abandon this policy and issue tax assessments in their normal manner for all taxpayers, including those who have participated in a Gifting Arrangement Tax Shelter.  The Nov 6, 2015 decision is contained in the Advocacy Section of our website.   Also, we are writing another letter to the new Minister of National Revenue with a request for intervention to ensure the CRA drops their unlawful policy.  The letter is also posted on this website  HERE.

OCT 23, 2015

The Tax Court has issued a decision on the Global Learning Giving Initiative (GLGI) tax shelter appeal for two cases for tax years 2004 and 2005.  The appeals were dismissed, which in simple terms means the GLGI program lost in Tax Court.  The decision was issued in a very short time, which comes as a surprise to most.   It is not sure if GLGI will appeal, they have until Nov 19, 2015 to file an appeal to Federal Court.  We will be posting more information on this situation in the not too distant future.  The full 57 page decision is posted in Section 5.3 of our Members Section.  This appeal is a different appeal than the one described in our Oct 18 news item.   

OCT 18, 2015

If you are a participant in the Global Learning Giving Initiative (GLGI),  there is an important event happening soon.   A group of approximately 130 GLGI donors have applied to Federal Court to have their case heard as a Class.   Initially , the case was heard by a Prothonotary who ruled in their favour.  The CRA appealed, and another Federal Court Judge ruled in their favour as well.  The CRA appealed again and now the case is being heard in Federal Court of Appeal,  180 Queen Street West, Toronto, ON,  Nov 17, 2015 at 2 pm.   

This is one of many battles that are underway on behalf of GLGI donors.   PGC will be attending the hearing.   If you can be in the area,  please take the time to attend this hearing.   When a Judge sees many interested people in the Gallery, it often affects his decision on behalf of the taxpayer.   If  you are a GLGI donor,   you can only do your cause good by attending this hearing, even if  you are not directly involved with this group.   We will have more to report on the other GLGI initiatives soon.

SEPT 24, 2015

We are very pleased to announce another PGC initiative for our Members.   A Group has formed for the purpose of defending themselves in Court against the CRA Reassessments for any of the four Pharma Programs  COIP, RLG, MLF, and PGI.  The PGC Board of Directors approved the funding request on Sept 23, 2015 and we have started the rather long but very optimistic process of legally securing our Members Tax Credits.   If you  participated in any of these for programs for any year(s),  we invite you to join the Group and let us help protect your rights.   Read More....

SEPT 22, 2015

CRA has appealed the McNally decision that we reported June 20.    It's hard to imagine how they could win on appeal, since two Federal Court Justices were in agreement on the CRA deterrence policy, however, it surely does buy them time.   We will determine and review the future actions planned now and prepare another report as soon as we can.

SEPT 14, 2015

The GLGI  Tax Court hearings started up again today in Vancouver and are expected to last the week. Robert Allen is again in attendance and his daily reports will be posted in the Members Section of this website. 

AUGUST 7, 2015

One of our Members and Directors has written another article regarding abuse by the current Government Minister of National Revenue.   You can view Robert Allen's article HERE.

JULY 24, 2015

Our President has written another letter to the Minister of National Revenue on behalf of all taxpayers who  have their tax returns held by CRA as deterrence for participating in a registered Gifting Arrangement.  You can view the letter here:   Letter to MNR   We continue to encourage all of you who participated to write your own letters.   We are hopeful that the  CRA will finally start obeying the law as decided by the Federal Court if we can put enough pressure on them.

JULY 21, 2015

The McNally Federal Court decision was a major victory for taxpayers who have their 2012 tax returns being held by CRA as a method of deterring participation.   The CRA has the right to appeal the decision, but they have not done so yet.  Normally, the CRA would have 30 days to appeal and that period has expired.   However, the Federal Court does not count July and August in their appeal periods, so CRA has until Sept 18 to register an appeal.   They did not appeal the Ficek decision and we don't expect them to appeal McNally either, but we won't know for sure until September.  In the meantime we are still asking all taxpayers affected to continue their written requests to the CRA to assess their returns being withheld.   Details on how to do this are shown HERE.

JULY 17, 2015

We understand that Merchant Law Group from Regina has started a Class Action against CRA on behalf of GLGI participants.  At this point , we have not done any evaluation of their action and are just making readers aware.  If anyone would like more information, please contact us or Merchant Law directly.

JUNE 29, 2015   - Time for Action

Based on the McNally case described below,  PGC believes it is now the proper time for taxpayers who have their tax returns being withheld (deterrence because of participating in a gifting arrangement)  to request again that CRA process their returns.   To assist our subscribers,  PGC has prepared a suggested "template letter" that taxpayers can send to their tax office.   If you are one of these taxpayers, we suggest you send this letter immediately to the CRA tax office that normally processes your return.   Here are the INSTRUCTIONS.


JUNE 20, 2015  -  Great News!

The Federal Court has rendered a decision on the McNally Mandamus application to have his 2012 tax return assessed.   Justice Sean Harrington agreed with McNally that CRA does not have the right to withhold his 2012 tax assessment for the main purpose of deterring him from participating in a gifting tax shelter.   CRA was  ordered to issue his assessment within 30 days.   When added to the Ficek case,  we believe this case will have a major impact on all other taxpayers in the same situation for 2012, 2013, and 2014.   We will soon be issuing instructions on what we believe to be the most appropriate actions taxpayers can take to be included in this decision.   The full decision, along with the Court's reasoning, is shown at the end of Section 5.4 of the PGC website Members Section.


JUNE 12, 2015

The Robert McNally Federal Court application for Mandamus to force the CRA to issue his 2012 tax assessment was heard on June 11, 2015.  This case could very well have a significant impact on all of the other taxpayers who have their returns delayed,  since McNally has also asked for a declaration on the CRA policy regarding Gifting Tax Shelters.   PGC attended the hearing and has prepared a summary of the proceedings in Section 5.4 of the Members Section of this website

JUNE 5, 2105

The Judge in the Rose Rae Class Action Mandamus case has finally  made a decision, having reserved her decision for six months after the original hearing.   This action was on behalf of all taxpayers who participated in a donation tax shelter in 2013.   Details of the decision are contained in the Members Section of our website.  


MAY 25, 2015

The Tax Court Hearings for the Global Learning Giving Initiative (GLGI) tax shelter started today in Vancouver.  The Hearing is expected to last 3 weeks..   As previously announced, Robert Allen,  Income Tax Consultant, is attending this Hearing and providing daily reports as well as a comprehensive final Due Diligence report that may be very helpful for participants who need to decide what to do with the CRA offers and reassessments.    The first of Robert's daily reports is posted in Section 5.3  of the Members Section of this website

APRIL 25, 2015

Due to ongoing requests, PGC has embarked on a National Tour of Free Seminars.   These seminar are intended to educate  taxpayers on the rights they have as a result of participating in a donation tax shelter. The topics include:

  • Dealing With the CRA Reassessments
  • How to Get the 2012/3  Tax Refunds
  • What went Wrong with the 4 Tax Shelters Currently Under PGC Investigation
  • How to Protect Yourself from Debt Collectors and Tax Collectors
  • How to Ensure the Best Chance Possible of Keeping Your Tax Refunds

Please  REGISTER NOW  to come and get informed of your taxpayer rights.

APRIL 16, 2015

You may or may not know that the Global Learning Giving Initiative (GLGI) tax shelter hearings are underway now in Tax Court.   Many of you have participated in the GLGI program over the years so these hearings and the final decision will potentially have a huge impact on you.  The hearings are expected to wrap up after the 3 weeks in Vancouver ending June 25, 2015.

Robert Allen, a former CRA Auditor and Appeals Officer,  is planning to attend the Vancouver hearings.   Bob is now an Income Tax Consultant with extensive knowledge of tax shelters, including GLGI.   Bob plans to prepare and  issue an exhaustive analysis of the hearings.   The benefits of obtaining this analysis are summarized as follows:

  • We will have an independent evaluation of the strengths/weaknesses of the court arguments a long time prior to the final decisions are made.  Bob will prepare a full report in layman's language.
  • Donors who face a decision as to whether or not to accept any CRA settlement offers will  have this evaluation to assist with their decision
  • The GLGI case may likely have a bearing on other "Trust Structured" programs , such as CHT , UHT, etc which are being held in abeyance right now.

Bob's full report will be posted in the Members Section of the PGC Website.   Bob will also be issuing daily updates from the Court House, which will also be posted in the Members Section of the PGC Website. We see Bob's initiative as a potentially great benefit to those of you facing a big decision with GLGI or one of the other "Trust Structured  programs.

If you are not a PGC Member, or your Membership has expired, we invite you to join our cause.   You can Register or Login to Renew your Membership HERE.

MAR 24, 2015

The Collections Agent for the Mission Life Financial tax shelter has been sending out notices to their clients.  The notices contain advice regarding the CRA 2011 reassessments that have been coming out recently.   PGC disagrees with a good portion of this advice, as well as some "Bad Advice" being given by certain former MLF sales agents.   You can see more details on this topic on our MLF Webpage.

MAR 14, 2015

The CRA has been issuing Settlement Offers to taxpayers for a variety of RPGA donation programs that PGC Members have used over recent years.   These offers are often very difficult to understand and confusing.   The CRA adds to the stress by giving short deadlines to respond to the offers.   PGC has prepared a summary of these offers in Section 5 of the Members Section of this website, with some information about what other Members are doing and why.   A PGC BLOG  article has been prepared to give additional guidance.

JAN 28, 2015

The CRA has started to issue reassessments for the 2011 Mission Life program.   These reassessments will require taxpayers to repay their tax refunds to the CRA unless they file a Notice of Objection within 90 days.   PGC has more detailed information on what taxpayers should do in the Members Section of this website.   If you are a 2011 MLF participant, don't miss the deadline!

JAN 17, 2015

There has been no decision yet on the Rose Rae mandamus application to Federal Court.  The Judge reserved her decision from the Dec 3, 2014 hearing.    There are more details in the Members Section.

DEC 17, 2014

Today we learned some very distressing news from CRA regarding the thousands of 2012 tax returns being held.   After giving us information to the contrary, CRA is now saying the 2012 tax returns will be held another year, until the fall of 2015 or potentially into 2016 before being assessed.   PGC finds this appalling news and invites taxpayers to join us in our fight against this abuse.    More information is contained in the Members Section.

DEC 12, 2014

The Canada Revenue Agency has begun delivering "proposal letters" for the 2011 Mission Life Financial RPGA.   Many of our Members have asked for guidance on how to respond.  PGC does not provide individual tax advice,  however,  we have published some comments and guidelines regarding this CRA letter in section 5 of the Members Section.   There is a critically important step that donors must take early next year.  Please login to access the Members Section.  

DEC 8, 2014

The Rose Rae application to Federal Court on behalf of 2013 RPGA donors had its certification hearing on Dec 3, 2014.   The certification hearing is needed to certify the action as a class action on behalf of all 2013 donors, before the case can be heard on its merits.   There is an additional update in the Members Section of our website.   The McNally application for the 2012 tax year still does not have a hearing date scheduled.   

DEC 6, 2014

A Third Interim Report for Investigation 13-001 into the alleged wrongdoing of the COIP, RLG, MLF, and PGI tax shelters has been prepared and issued to Members.   You can see the full report here.

NOV 2, 2014

We are continuing efforts to obtain the tax assessments for Members who participated with an RPGA in 2012 and 2013.  A recent update has been posted in the Members Section.  Please login to view.

OCT 28, 2014

In early 2013,  PGC undertook a review of the Justice Pharma program to determine if the program was a proper method of settling the donation debts related to the COIP, RLG, MLF, and PGI  RPGA programs.   The review resulted in a PGC endorsement of the Justice Pharma Program.    After more than a year,  PGC has undertaken another review to determine if the Justice Pharma program continues to be an appropriate method to settle donation debts.  We also wanted to confirm that Justice has actually delivered on what their contracts outlined.   This second review has resulted in PGC  wholeheartedly renewing its endorsement of the Justice program.   You can see the full details of the review by clicking here.

OCT 7, 2014

Some years ago, the Federal Government changed the regulatory regime governing Not For Profit organizations in Canada.   The new laws increased the scope of regulation and required Not For Profit corporations to create new governance By Laws.  Corporations were given some time to comply with the new regulatory regime.   PGC is pleased to announce that we have completed the transition to the new regime and have been granted a Certificate of Continuance from Industry Canada.  You can see the certificate by clicking on the link.

OCT 2, 2014

While PGC has been busy over the summer, it has been somewhat quiet on the CRA front.   It has also been relatively quiet with the debt collection activities from the Group under PGC investigation.  We believe however, that things are about to change.   As a result of this, and to help Members prepare for what we believe will happen, we have issued another Alert A14-11    Please click on the Alert to see the details.

SEPT 24, 2014

It has been a very busy summer for PGC, working on many fronts to assist Members and protect their rights.  Here is a quick summary of the activities undertaken:

a)  The legal strategy and actions to obtain refunds for 2012 and 2013 RPGA participants have been re-jigged with an objective to speed up the process.   There are now two court actions underway and members can review the status of these actions in the Members Section of this website.

b)   The current investigation into the alleged wrong doings of several RPGA programs moved forward with some interesting but disturbing results.  Another interim report will be published later this fall.

c)   A sufficient number of Members have complained to PGC about the actions taken/ not taken by the independent agents who sold them participation in the  COIP, RLG, MLF, and PGI programs.   The complaints range from agents just not supporting their clients anymore, to agents providing advice and information  that may be incorrect or problematic.   As a result, PGC has launched another investigation  14-001  into the actions of these agents and will be posting the investigative process and ongoing results on this website when available..

PGC continues to work diligently on behalf of all its Members, even though the head wind is often stronger than anticipated and therefore progress can be slower than we all hope for.

JULY 12, 2014

We are pleased to announce that Paul Lauzon has agreed to join the Board of Directors of PGC.   Paul has been acting as Chairman of the BC Provincial Affairs Committee for several years now and has been a staunch advocate of Profitable Giving and our organization.   We welcome Paul's experience and knowledge as the PGC Board deals with several difficult and important issues on behalf of Members.   Thank you Paul for your service, we appreciate your dedication to protecting our Members.


JUNE 30, 2014

Profitable Giving Canada  has moved its head office to London, Ontario effective July 1, 2014.   The new office location provides expanded reception and meeting facilities and will help us serve our members better.   The new address is as follows:

Profitable Giving Canada
380 Wellington Street
Tower B, 6th Floor, Suite 600
London, Ontario
N6A 5B5

MAY 18, 2014

The Tax Court of Canada has issued a recent ruling that is very interesting.   A group of taxpayers claimed tax credits coming from charitable donations that were claimed to have "inflated receipts"    The CRA argued that these "inflated receipts" from the charity should negate the entire gift, since the taxpayers paid only 10% of the value of the donation and received a greater benefit back in the form of the tax credit.   CRA reassessed the taxpayers to zero for the whole donation.    The Tax Court, however, ruled that inflated receipts, and the associated tax credit, do not in themselves constitute a benefit  that would allow CRA to reassess to zero.   This affirms a very important principle for certain recent RPGA programs that have been reassessed to zero for the same reason.  You can see more details of the case here:  Ronaldo David vs the Queen


APR 17, 2014

A  CTV  Vancouver television station has recently broadcast two short pieces on tax shelters.  PGC does not normally respond to media broadcasts, however, several of our members were so appalled at the inaccuracies and one sided opinions expressed that we were asked to respond.   You can see the PGC response posted here.  Robert Allen also responded to CTV.  You can see his response here.

MAR 20, 2014

Another update on our Mandamus application has been posted in the Members Section of our website.  Please log in to see the update.


FEB 26, 2014

Our application to Federal Court in the form of Mandamus to have the CRA issue donor 2012 tax assessments is progressing slower than anticipated.  The CRA appears to be incorporating stalling tactics, however, we are pressing on as quickly as possible.  If you are a Member, please log in and click the Members Section Link to see a more detailed update.


FEB 6, 2014

It is now confirmed that Integrated RM Inc, is registered as a collection agency in Ontario, and likely the other provinces they claim on their website.   This makes matters worse, since it lends legitimacy to their collection efforts, however, their tactics remain questionable at best.   PGC has updated its Alert A14-10


FEB 4, 2014

Fast Track Tax Strategy has again sent out emails to clients  with suspect tax advice. This advice was the subject of a previous Alert A13-15.    Additionally , Fast has made false and misleading statements regarding PGC.   Fast has not taken the time to look into the facts regarding  PGC.   PGC has prepared a summary of the Fast message and the correct facts that should have accompanied it.   You can see it here as Exhibit A to this news item..

JAN 31, 2014

PGC has issued an Alert A14-10 regarding the new collections company Integrated RM, Inc.  It appears this company was created to intensify the debt collection activities of the RPGA programs presently under investigation by PGC.   Members and Subscribers are encouraged to review the ALERT.

JAN 20, 2014

The Affidavit to have the Mandamus Application certified as a Class Action has been filed in Federal Court.  Members are encouraged to log in to the Members Section to review the details.  It is still not too late to join the class demanding CRA process 2012 tax returns.

DEC 30, 2013

The PGC Mandamus Class Action has been filed in Federal Court !  If you want to be added to our list to have the CRA process your 2012 tax return, please apply here.   It is not too late.

DEC 18, 2013

The legal process for the PGC Mandamus class action application to Federal Court has been finalized.   If you are a PGC Member, please log in  and go to the Members Section to see all of the details on how to formalized your participation.   If you are not a PGC Member, it is not too late to become a Member and have PGC represent you.  If successful, our Mandamus will  force the CRA to issue your 2012 tax assessment immediately. 

NOV 28, 2013

The CRA continues to withhold taxpayers 2012 tax returns as ransom for withdrawing claims for valid tax credits.   The PGC Mandamus legal action is proceeding more quickly now, and there will be a further update to those members who are on the list soon.   There is still time to have members names added to our list, if you wish PGC to represent you with the CRA on this issue.   Please just let us know.

The consequences of the CRA action are having very negative ripple effects for many taxpayers.   Robert Allen has written an article on this, published by the  Vernon BC  Capital News.  Click on the link to see it, and add your comments to the blog.   PGC is taking the leadership role necessary to protect our members rights and force the CRA to comply with the law of the land.   

OCT 18, 2013   REV

Many PGC members will know Kara-Lee Burke as a staunch advocate of Profitable Giving for many years.   We are sad to hear that Kara-Lee has decided to move on to different endeavours and has left the country.   We wish Kara-Lee all the best.
Kara-Lee is also owner of Justice Trading Canada, a company that previously performed administrative services for  Justice Trading Ltd (BVI).   With Kara-Lee's departure, Justice Trading Ltd, (BVI)  has transitioned the full administration over to its growing team of Canadian affiliates and its head office staff.  The Canadian affiliates continue to assist donors compliantly settle their donation debts.  Thousands of donors have already taken this step.    The Justice Pharma program is a totally independent debt settlement program, and the only known program available that is endorsed by PGC.

OCT 15, 2013

PGC has had an incredible response to the proposed mandamus action to force the CRA to issue 2012 tax assessments.   To date, well over 300 people have been added to the list for legal assistance.   If you would  like to add your name for help getting  your 2012 tax assessment, please see here for details.  PGC has extended the target date for a final list to Oct 31, 2013.

OCT 8, 2013

Minister Findlay has responded to one of PGC's earlier letters to her and Gail Shea.  It probably crossed in the mail with PGC's  Oct 1, 2013 letter since they are both of the same date.  The letter is a totally unacceptable response as you can see here.   This response only cements our view that there is only one solution to stop the withholding of taxpayers' 2012 returns.   On a positive note, the number of people signed on to our mandamus list has been growing fast and is now at 171.   If  you want to be added to the list for legal action, please look here.   PGC would like to offer special thanks to all new members who have signed up recently.

OCT 1, 2013

PGC now believes that the CRA and the Minister of National Revenue are intent on following their RPGA deterrence policy of withholding tax assessments.  Complaints and letters continue to go unanswered and will likely remain so.  Based on the overwhelming Member response to the proposed mandamus application, PGC has decided to fund a Member group's application to federal court from the Universal Participant Protection Fund.     You can see details here.  If you are waiting for your 2012 tax return, we strongly urge you to become a Member and join the group.  

SEPT 10, 2013

PGC has received a large number of requests from Members to participate in an application to the Federal Court for a mandamus order to compel the Minister of National Revenue to issue their 2012 tax assessments.  This process  is currently under review by PGC and it may be the only way to have the CRA comply.    GLGI has reported some success with their legal arguments on behalf of their donors.   If you would like to join the PGC group to have your name listed on the mandamus application, please use the Contact Us form and choose the Category   "Add my name to the MNR Mandamus Application" 

SEPT 4, 2013

PGC has written another letter to the Minister of National Revenue regarding the CRA withholding of 2012 tax returns.   You can view it here as one of the Documents.  PGC is requesting you continue to write to the Minister as shown below.

AUGUST 22, 2013

The Minister has not responded to any of the correspondence from PGC or individual members as of this date.   One member called the CRA Winnipeg office and received the following response.   Please continue to write to the Minister as shown on our August 2 update.  Also, if you have not signed our petition, please do so.   PGC will be working hard to get this issued resolved one way or another as soon as possible.

AUGUST 2, 2013

PGC has written an Open Letter to the CRA regarding the continued abuse of  taxpayer rights over the withholding of 2012 notices of assessment.   We are asking all Members and subscribers to write/email the Minister of National Revenue with a request to intervene to stop the abuse.    Please read the letter and help with the cause.  Contact Information is Available Here.   Many voices cannot go unheard.

JUNE 26, 2013

Today, the Harper Government announced a new right added to the Taxpayer's Bill of Rights.   Taxpayers now have the right to be treated fairly by the Canada Revenue Agency, and lodge complaints or requests for formal review without fear of reprisal.  See the NEWS RELEASE HERE.   It is interesting to see this initiative come at the same time that many taxpayers are complaining about their treatment by the Winnipeg Tax Centre  (see June 2, 2013 news item below) 

JUNE 23, 2013

We are pleased to report that Robert G. (Bob) Allen has been appointed to a term on the PGC Board of Directors.   Bob has served for almost 2 years now as Chairman of our Peer Review Board Committee and has contributed significantly to the goals of PGC since becoming a PGS member.   Bob's knowledge and experience will be appreciated by the Board when important decisions are made.   Welcome Bob !

JUNE 2, 2013

It appears the good news announced May 15 is not coming true.  The CRA continues to defy the Federal Court ruling and is still asking taxpayers to withdraw their claims for tax credits associated with Gifting Arrangements.    PGC feels this is not only unfair and discriminatory, but potentially illegal.   We urge members and any other interested parties to sign our Petition to the Minister of National Revenue.   As a group, we can make a difference.

MAY 30, 2013

PGC has received several member requests for information and advice on the Parklane tax shelter program.  To date, PGC has passively monitored what is happening with Parklane, but not set up any committee to study the activities in detail.   If we receive sufficient requests, PGC will ask for member volunteers to create the appropriate forum for member assistance.   Please use the Contact Us - Committee form on this website.


MAY 15, 2013

Great news for GLGI donors and participants in other registered tax shelters.   The Winnipeg CRA office policy of withholding refunds until the audit has been completed  (several years) has been struck down by the Federal Court.  GLGI's motion is a clear precedent that the CRA cannot use  withholding of assessments as a way to deter donation tax shelter participation, regardless of whether or not the authorities believe it is a sham and a fraud and in contravention of the Income Tax Act of Canada.  The merits of the program itself are irrelevant next to the overriding principle that the CRA, despite its vast discretionary powers, has the statutory duty to assess with all due dispatch.

This should be more than sufficient to compel the CRA to assess all participants' returns despite their participation in a donation tax shelter, and regardless of whether it has been reassessed for years.  If you are one who has received the letter denying your assessment,  you should call or write to them and quote this case.  You can see the Court Decision Here


MAY 1, 2013

It now appears that COIP has issued the same demands for money that RLG and MLF have done. There is a new company introduced: SUN Rx. This is not the same company that Google will show you, but rather another private company associated with the promoters. The debt settlement company is again Integrated Receivables Management Inc.    PGC recommends against using any of these companies for debt settlement for the reasons outlined in the ALERT of April 23, 2013.

APRIL 23, 2013

Relief Lending Group has issued a request to donors to settle their debts through their affiliated company Integrated Receivables Management Inc.  It is PGC's belief that this is an unwarranted demand for more money from donors and seriously jeopardizes the end position of the donors tax credit.   PGC has issued an ALERT for this initiative.

APRIL 3, 2013

More collection letters are appearing in donor's mailboxes from Relief Lending Group and Mission Life Financial.  The situation appears to PGC management to be a repeat of the 2008 collections efforts.   Members are urged to review the PGC ALERTS on this topic before making an informed decision on their course of action.

MARCH 22, 2013

After extensive review and evaluation,  Profitable Giving Canada has granted its endorsement to the Justice Pharma Program.   This program provides an excellent solution to the dilemma that many participants in certain RPGA  (tax shelter)  programs are facing.   Many donors/participants are facing debt and interest collection activities associated with their participation in the RPGA.   These debt/interest  collection activities are perceived to continue until such time as the donor/participant can settle the debt properly.   Up until the creation of the Justice Pharma Program, there was no compliant and practical debt settlement process available to donors/participants.  PGC applauds the initiative taken by Justice Pharma to assist these donors/participants to compliantly settle their debts.

The PGC Debt Settlement Committee 2012 mandate can be seen here

The legal opinion on the Justice Pharma program can be seen here

More information on the Justice Pharma program is available here:

Debts owing to the following RPGA programs may be settled using the Justice Pharma Program

Canadian Organization for International Philanthropy (COIP)
Relief Lending Group Ltd  (RLG)
Mission Life Financial Inc  (MLF)
PharmaGifts International  (PGI)
 JANUARY 28, 2012
 Profitable Giving Canada moves its head office to Windsor, Ontario.   The notice was published in the Canada Gazette of the same date.   Notice
DECEMBER 17, 2012
PGC introduces a new ALERT system to provide Members with news and alerts related to important issues affecting Members.  More details here