In appealing a revocation of its charitable registration, the taxpayer argued that the registration of charities was ultra vires Parliament, as it fell within s. 92(7). Rejecting the taxpayer's appeal, Sexton J.A. stated for the Court at para. 8:
We have not been persuaded that there is any merit to the Appellant's argument that the provisions of the ITA dealing with the registration and deregistration of charities are an unconstitutional infringement on provincial legislative authority. In our view, these provisions relate, in their pith and substance, to federal taxation, and accordingly they are intra vires the Parliament of Canada under subsection 91(3) of the Constitution Act, 1867. Both the advantages of registration and the drawbacks of revocation relate solely to the tax treatment of charities and their donors. They do not impermissibly affect the affairs of charities in any other way, nor do they impede provinces from otherwise regulating charities.