We
explained recently that Imagine Canada had reported further
guidance from Industry Canada about CASL's charitable
fundraising exception.
Imagine Canada has issued a further update reporting that it has
been contacted by the CRTC (one of the other entities responsible
for regulating CASL), and that the CRTC indicates that it
interprets CASL's fundraising exception differently from
Industry Canada. Although the CRTC has yet to provide any official
guidance, it apparently has indicated that it will be releasing an
FAQ about charities in the next few weeks (though presumably after
CASL is already in force).
This episode highlights an ongoing problem with CASL's
implementation, namely, a lack of comprehensive guidance on
CASL's many intricacies, combined with ongoing inconsistency in
the guidance that has been issued by various regulators.
