Non-profit annual filing checklist: CRA and Ontario

Start by identifying what kind of organization you are

The filing list depends on your status, and the labels are not interchangeable. A non-profit organization, in the CRA’s sense, is a club, society or association that is not a charity and is run solely for purposes such as social welfare, civic improvement or recreation, with no income available for the personal benefit of members. A registered charity is a separate category that has applied to the CRA and been accepted. A non-profit cannot issue official donation receipts; a registered charity can.

Separately, you may be incorporated as a not-for-profit corporation under Ontario law. Incorporation is a provincial status; it does not by itself make an organization a registered charity or exempt from tax. If you are unsure which description fits, settle that question first with your board and an accountant, because every other deadline follows from it.

Federal: the T1044 non-profit information return

A non-profit does not file a T1044 every year automatically. Under the CRA’s guide, it generally has to file for a fiscal period if it received, or was entitled to receive, more than $10,000 in taxable dividends, interest, rentals and royalties in the period, or if its total assets were more than $200,000 at the end of the previous fiscal period. Once it has filed one, it has to keep filing for every later period while it remains a non-profit, whatever the amounts.

The return is due no later than six months after the fiscal period end. The basic late penalty is $25 a day, with a minimum of $100 and a maximum of $2,500, and the CRA can waive penalties for extraordinary circumstances. Registered charities do not file the T1044. The return reports membership dues, grants, investment and rental income, gifts, assets and liabilities, remuneration and the number of members, so your year-end records should be organized to produce those totals.

As an illustration, a club with a December 31 year-end that earned $4,000 of interest and $7,000 of rent in the year has crossed the $10,000 property-income line and would generally file for that year, with the return due by June 30. Note that the test looks at amounts received or receivable, and the rental figure is reported before deducting related expenses, so expenses do not bring the total back under the line.

Federal: T2, T3 or T3010

The T1044 is an information return, not a tax return. The CRA’s guide says a corporation generally has to file a T2 corporation income tax return or a T2 short return even if it is a non-profit, and an organization whose main purpose is to provide dining, recreational or sporting facilities may instead have to file a T3 trust return. Your accountant should confirm which applies; see the guide on corporate tax filing versus payment for how T2 deadlines work.

A registered charity files the T3010 registered charity information return no later than six months after its fiscal period end. A fiscal period ending December 31 gives a June 30 due date. The CRA may revoke the registration of a charity that does not file, and a revoked charity can no longer issue official donation receipts, is no longer exempt from income tax, and must either give its remaining assets to an eligible donee or pay a revocation tax.

Ontario: the annual return and updates

Ontario corporations, including not-for-profit corporations, must file an annual return through the Ontario Business Registry each year within six months of their fiscal year-end. Filing requires an Ontario.ca login, an Ontario Business Account and the corporation’s company key. Keep that key private, and share it only with someone you trust to file for you.

The registry also expects changes to be reported within 15 days, including to the official email address, so that you receive ministry notices. Directors and officers change often in volunteer-led groups, so assign someone to update the registry after each annual meeting.

Payroll, records and the board

If you pay anyone, the usual employer duties apply: source deductions, remittances and year-end slips. The first payroll checklist and the term on payroll remittances cover those. Keep payroll records and any information slips you issue, as the CRA expects employers to retain them.

Generally, keep records and supporting documents for six years from the end of the last tax year they relate to. Records about property and the share registry, where they apply, have to be kept indefinitely. Keep the board involved: present the year-end statements to it, record decisions about remuneration and payments to members, and keep a calendar of due dates with a named owner for each filing.