Open Letter: Kevin Perkins, Executive Director of Farm Radio International, Expresses Support for the Effective and Accountable Charities Act

In this open letter, Kevin Perkins, Executive Director of Farm Radio International, expresses strong support for Bill S-222, the Effective and Accountable Charities Act.

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May 7, 2021

The Honourable Senator Ratna Omidvar
Senate of Canada

Dear Senator Omidvar,

I am writing to express strong support for Bill S-222, the Effective and Accountable Charities Act. Thank you for your leadership on this important initiative. The Bill provides a pragmatic, responsible, accountable and just solution to an issue that has been of concern to Canadian international development charities like Farm Radio
International for many years.

On March 18, 2019, I was invited to speak as a witness before a Special Senate Committee on the Charitable Sector that you co-chaired. In my address to the Committee, I noted that the direction and control provision of the Income Tax Act means that a charity like Farm Radio International can only work with a partner organization in another country – such as a community radio station or women’s group, or a national health organization – if it contracts it as an “intermediary” to implement its own activities under its direction and control. Charities cannot offer contributions to local organizations to enable them, for example, to advance their own compatible charitable activities.

This is problematic for Canadian charities involved in international development. Our ultimate success depends on supporting local development partners as they work to become more effective and sustainable organizations in their own countries. If these organizations are simply contracted as “intermediary” service providers that work under Canadian direction and control, their critical leadership in effective development is diminished, undermining the long-term goal of self-reliance. It can have the unintended effect of maintaining a colonial relationship between Canadian charities and their southern partners. It is also contrary to the Government of Canada’s own policies for providing international assistance to civil society partners – policies that require Canadian NGOs to follow partnership principles of local ownership, participation and inclusive decision-making.

Of course, Canadian charities must retain fiduciary responsibility for the use of the funds entrusted to them. Transparency and accountability are essential, particularly when tax-creditable Canadian philanthropic donations are concerned.

Bill S-222, the Effective and Accountable Charities Act, strikes a critically important balance: charities like Farm Radio International will be able to establish equal and respectful partnerships with non-charities, including southern civil society organizations, while maintaining a very high standard of accountability and transparency.

It is my strong hope that the Senate will favour this important Bill so that it may replace the “own activities” and direction and control provisions of the Income Tax Act.

Best regards, 

Kevin Perkins
Executive Director, Farm Radio International

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