In the midst of another Canada Post strike, what are charities to do?
It is always a good idea to check newsroom updates from Canada Revenue Agency (CRA) and sign up for the Charities newsletter. There, you will find suggestions on how to handle any disruptions caused by the strike. Below, you’ll find more information on two key issues that arise in a postal strike: reporting and receipting.
Reporting
CRA encourages charities to file annual information returns (T3010) online using My Business Account (MyBA). If your charity does not have a MyBA account, you can register online.
If that is not possible, alternative filing options may be available. Contact CRA to discuss the best option for your organization.
Receipting
Again, charities can contact CRA with questions about receipting gifts and issuing donation receipts. However, it is helpful to understand the general rules regarding receipting donations received by mail first.
Receipting Regulation
The starting point for any receipting question is to look at the Income Tax Regulations, Regulation 3501. It explains that:
- Where the gift is a cash gift, the receipt must show the date on which, or the year during which, the gift was received
- Where the gift is a gift of property, the receipt must show the date on which the gift was received (among other things)
Receipting Donations Sent by Mail With Postmark
When donations are received by mail, the Canada Revenue Agency considers the date of the donation to be the date of the postmark on the envelope. Your charity must retain the stamped envelope as part of its books and records.
Receipting Donations Sent by Mail Without a Postmark
When donations are received by mail without a postmark, your charity must be consistent and demonstrate good faith in how the donation is processed and recorded.
For example, at year-end, if the envelope arrives along with other envelopes all postmarked December 31, and the donation cheque is dated for the prior year, it may be reasonable to include it in the prior year. If the envelope arrives along with other envelopes that have mixed postmarked dates, it may be reasonable to include it in the new year.
Year-End Donations
The 2024 Canada Post strike created uncertainty for year-end donations and the receipting process. This year’s strike has started two months earlier, so hopefully it will also be resolved earlier. But if the strike is lengthy, two simple steps include (1) be consistent, (2) consider using cut-off dates.
Receipting Donations Consistently
It is up to your charity to set its own policy on how it will treat end-of-year donations. Your charity may choose to (1) determine, using postmarks, whether the donation should be receipted for the current year or (2) treat any gift delivered on or after January 1 as a gift for the new year.
Your charity should be consistent in this choice and should advise donors ahead of time. Your approach should be outlined in a gift acceptance policy, ensuring that staff, stewardship representatives, fundraisers, and donors are all aware and informed.
Cut-Off Dates
Your charity may also choose to incorporate a ‘cut-off’ date that is determined each year, depending on the calendar, holidays, and staffing – e.g. the Friday ahead of New Year’s Day when that day falls on a weekend. A simple addition to your gift acceptance policy can address year-end gifts.
The postal disruption will make determining the date of the donation challenging. It is possible that some gifts may not be postmarked until the new year, though intended for the 2025 tax year, or that some gifts may not be postmarked at all.
You can read more about receipting year-end donations in our 2024 blog post.
Additional Resources
We’ve got more information on official donation receipts in our Member Knowledge Base, and you can catch up on conversations about MyBA in The Green.
The content provided in this blog is for general information purposes and does not constitute legal or professional advice. Every organization’s circumstances are unique. Before acting on the basis of information contained in this blog, readers should consult with a qualified lawyer for advice specific to their situation.