Sigma Chi Canadian Foundation v. Canada (National Revenue), 2024 FCA 59 -- summary under Paragraph (a.1)

CRA found that the appellant (Sigma Chi) provided funds to non-qualified donees by making loans to Sigma Chi fraternity housing corporations, established to provide housing to members, and also failed to obtain security for its loans to such corporations. It also found that Sigma Chi failed to maintain direction and control over the Horizon Scholarship program, a program partially funded by Sigma Chi and administered in the United States. (It had only one of the eight seats on the governing board, and only two of 16 on the selection committee, so that it did not have direction and control over the use of its funds.) Laskin JA found no reversible error in the Minister’s finding that Sigma Chi had thus failed to comply with s. 149.1(1)(a.1).