A. INTRODUCTION
It has been over three years since the Honourable Joe Oliver,
then Minister of Natural Resources, fired the proverbial shot
across the bow in the political activities debate by releasing his
unprecedented "open letter" on January 9, 2012. The
letter did not explicitly target registered charities, but rather
"environmental and other radical groups" threatening
"to hijack" the regulatory system "to achieve their
radical ideological agenda" and delay government supported
projects "to undermine Canada's national economic
interest."1 However, given the timing of his
comments, the House of Commons Standing Committee on Finance's
("Standing Committee") December 15, 2011 announcement of
its study on charitable giving, as well as other public statements
by the federal government, many in the sector and media speculated
that the federal government was utilizing Canada Revenue Agency
("CRA") to take aim at environmental charities under the
guise of reviewing
