Canada Revenue Agency
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Policy Commentary

Release Date
December 17, 1997

Reference Number
CPC-013

Subject
Charitable purposes - Relief of poverty - Advancement of education - Whether providing computers to poor children for educational purposes constitutes a charitable purpose

Purpose
To clarify the Directorate's policy regarding organizations established to provide computers to poor children for educational purposes.

Commentary
  1. Providing computers to poor children does not fall squarely within the relief of poverty as a category of charity. A computer is not a basic amenity of life in the same sense as food or lodging.

  2. Providing computers to children does not fulfill all the expectations normally required for a purpose to fall within the category of advancement of education, in the same way as a book, by itself, does not advance education.

  3. It is incorrect to view the categories of charity as functioning independently from each other. A purpose need not fit only within one of the categories. The best example is that of an educational scholarship based on financial needs. One can easily argue that it falls either within the relief of poverty or the advancement of education.

  4. A computer is a tool that opens the door to a new kind of literacy and new, contemporary skill-sets. Providing one would be the same as purchasing pen and pencil sets, or required school texts for needy students.

  5. An organization established to provide computers to poor children so that they are not hindered in relation to other more fortunate classmates, and do not have to go through the entire educational process from a disadvantaged position could qualify for registration. The basic amenity that is provided to poor children is education rather than the computer by itself.

  6. Since computer literacy is gaining more and more importance in the context of a full education for younger generations, an organization should rely, in selecting its beneficiaries, on a referral from a school, as well as a means test. The referral should attest that

    1. computer skills are an important and essential part of that school's established curriculum, and the proper carrying out of the curriculum requires that all students enrolled at the school in a given program, have regular access to a personal home computer, or

    2. a significant majority of students enrolled at the school, in a given program, do in fact already have access to a personal home computer purchased by parents, and the particular candidate would be in a disadvantaged learning position by not having access to one.