Recently a friend asked about a “tax scheme” that claims to buy medicines for AIDS patients (“Fight AIDS Save Taxes” is its slogan) in Africa and provides a tax receipt for four to five times the donation amount. While stiffing the government, helping AIDS patients and putting some money in the pocket may sound like a win-win situation all around, participating in a tax shelter scheme is asking for trouble. The Canada Revenue Agency has a clear position on these schemes and titled a recent alert, “Warning: Participating in tax shelter gifting arrangements is likely to result in a tax bill!” The text of the alert also provides no room for confusion:

New schemes are being marketed that claim to be different from those for which the CRA has previously issued warnings. Taxpayers should avoid all schemes that promise donation receipts for 3 to 4 times the cash payment. It is the CRA’s position that the proposed legislation, effective since 2003, will apply to reduce the donation credit to no more than the actual cash payment. Furthermore, as indicated above, completed audits have shown that there was effectively no gift being made in many cases, and as a result, the donation was reduced to zero.

The Toronto Star ran a series of investigative pieces on charity scams last year available here, here and here. An accompanying graphic to the story illustrates the risk involved in these schemes. A taxpayer made a donation of $10K and received a tax credit of $21K (probably adjusted for the original donation), got audited and the taxman wants $35K in back taxes, interest and penalties. Despite the CRA warnings and media coverage, it appears that many are falling for these schemes — the aforementioned “charity” claims to have raised $165 million so far.

This article has 684 comments

  1. One of the promoters of ParkLane was Roy Beyer, who is now Director of Marketing with Foundation Capital Corporation / Harvest Capital. Harvest has also marketed some questionable investments, including ‘The Land Development Company” and “Payday Today USA”. Google to find out more.

  2. My wife and I investigated 4 charities that suit our tastes, and those are the only ones to which we donate. All the cold callers, no matter how good their causes may be get turned away politely.

  3. Old adage “you can’t cheat an honest man (or woman)” comes to mind. This little saying has literally saved me thousands of dollars whenever someone comes up to me and tells me about the latest money saving endeavour that sounds too good to be true.

  4. Canadian Capitalist

    Scamhater: Like the Toronto Star says, it is astonishing that these “charities” simply shut down and start another when they are audited. I would think that they should be prosecuted because fraud is a crime and should be treated as such.

    Al: We have a handful of charities we support and the only exception I make is for young children who knock on the door (they don’t give out gift receipts though).

    Novice: I agree with you that “give $10 and get a $50 receipt” does not pass the BS test. And the CRA issues tax alerts every year and tax payers who participate in these schemes can’t say they weren’t warned.

  5. Canada Revenue Agency has an informative and free speaker’s kit on charitable donations which covers donation scams. It includes a PowerPoint presentation, pamphlets etc. and is ideal for investment club discussion. Find out more here:

    Gail Bebee
    Author of No Hype-The Straight Goods on Investing Your Money

  6. Hmmmm. CRA issues charitable status to a charity (which they presumably investigate before doing so), then decide that it’s not a charity after all, and those who have donated are screwed?

    While I understand fully that these charities are used to structure the tax shelters, and that it’s very much ‘buyer beware’ when using such a shelter, it’s not as simple as those above make out.

    CRA is an extra-legal organization which bullies people into paying taxes they may not owe, and will not provide clear guidance as to where the lines are. Just call CRA 3 times with a complex question, and usually you will get 3 different answers. Ask them to put it in writing, and they won’t.

    Why can’t CRA investigate a tax shelter before issuing a tax shelter number?

    And I hardly think that regurgitating vague, threatening ‘Alerts’ from CRA (why don’t they specify, name names?) and quoting the shoddy financial journalism of the Toronto Star passes as wise counsel from the Canadian Capitalist. Sad.

  7. Canadian Capitalist

    Gail: Thanks for the link.

    Brad: The CRA simply registers a charity initially and assumes that they will collect donations and spend it for charitable purposes. They do audit and revoke registrations but how are they going to tell a good charity from bad at the time of registering?

    It is a good question why the people running these charities are not prosecuted when they are found to be frauds. I don’t have an answer to this.

    But, I don’t find anything vague about CRA’s alerts. They specifically mention that if the receipt is many times the donation, the taxpayer is taking a risk of the charitable contribution being denied and interest and penalties applied.

    The Star’s series has named names, pointed out the abuses of the system and demanded action. How is that shoddy journalism?

  8. Whow CC, you sured failed Brad’s high standards this time. Didn’t I read somewhere on your site that you do not purport to be an ‘advisor’ and therefore nothing on this site can be construed as ‘advice’ (or ‘counsel’)?

    Moving right along, thanks for the heads-up, I will be investigating the ‘shoddy financial journalism’ of The Star next. I fear investors will fail to recognize to-good-to-be-true schemes for what they are until the end of time.

  9. If something seems to good to be true, it usually is.

    I am suprised at the number of people I know that gave money to these types of scams for the sole reason that they could get a deduction in excess of what they paid.

    I know one guy who “doesn’t believe in RRSP’s” but was keen to throw $5,000 at one of these scams. Ridiculous.

  10. CC, not to discourage you from giving to kids (I do as well) but you mentioned:

    “Al: We have a handful of charities we support and the only exception I make is for young children who knock on the door (they don’t give out gift receipts though).”

    Down here it became a big scam for kids to go door to door “raising funds” for something and just pocketing the cash, so residents were advised that if it is a real charity, it should have a receipt, and if it is fundraising for something else (such as a school trip) then the student should show an official letter from the school indicating such.

  11. Unfortunately, the scams out there hurt many legitimate tax shelter programs which don’t involve the dreaded “inflated receipts”, etc.

    Question: If a program existed which didn’t harm the charities & followed the letter & spirit of the law exactly ( i.e. – no GAAR), do you think the CRA could EVER afford to say it was “okay”?


    Get real people – The CRA has an agenda, and even though the law allows for tax avoidance and defines “tax shelter” in the income tax act, the CRA can never afford NOT to challenge a program or everybody in Canada would participate & never pay tax again!

    Focus on the LAW – not your feelings, newspapers, or the CRA and you will have your answer as to whether a tax shelter program “works”.

    I guess none of you happened to read the retraction that very journalist did on the above mentioned article. Check it out at:

  12. The Toronto Star article was overly simplistic and clearly written by someone not drilling down on the analysis and painting the entire industry in one broad-stroke. It would be equivalent of them writing that all finance blogs give improper information.

    Like any other investment product, there are good ones and there are bad ones. The legitimate tax shelters have been challenged by CRA and, the majority of them, have survived court challenges (the tax lawyers who advise and give opinions on the legitimate ones are a who’s who of the corporate tax bar in Canada; you have lawyers charging $800 per hour against a government lawyer who wants to leave at 4:30 every day- hardly a fair fight). The reason why you never hear of CRA losing these challenges is because the original legitimate tax shelters had a minimum buy-in that precluded most middle class citizen (usually starting at cash contributions over $25,000) so why would a media outlet like the Star report on that?

    As with all things, greed took over and the products went retail. This is when the scams began to happen and because of the number of people claiming credits CRA had to act to defend its bottom line.

    There’s good tax shelters and bad ones. If the entire concept of tax shelter make your eyes glaze over. Avoid the entire industry.

    Of course, I would like to point out, from the all the background noise, what the real problem is. If the tax rate was actually fair and low there would be no need for this entire industry- good or bad. Let’s remember why we all spend countless hours looking at shelters and figuring out ways to deduct interest off our mortgages etc. We all feel our taxes are too high and attempt to find ways to minimize them.

  13. Excellent points!

    I agree entirely…


  14. Pingback: No Fee Banking, Cheap Books and Roundup - Aug 22, 2008 | Million Dollar Journey

  15. I worked for a fundraising company a few years back. They raised money for questionable and not so questionable groups. And regardless of their real merit, if you’re being propositioned with an offer for charity giving then just simply don’t do it.

    The company I worked for never exceeded 22% for actual “charitable offerings.”

    And that’s a high number for the “fundraising industry.”

    Never give to solicitors of any kind, unless you truly believe it’s worth it simply to help your local (for canvassers) or international (for telemarkets) job markets.

    Pick a charity. Research it as you would a stock, to ensure the money might accomplish *something* and then enjoy your minor tax benefit.

    Charitable giving should be about doing something you believe in, not a minor tax deduction. It’s one place that I simply can’t find selfishness to be ironic.

  16. Canadian Capitalist

    Column in the Globe and Mail that CRA says a charity is running a tax-shelter scheme:


  17. Yes, this charity works with a “Trust structure” (warned against by the CRA) called CHT (Canadian Humanitarian Trust).

    These type of programs are worse than the “buy low, donate high” programs of old as they are buy NOTHING and donate high.

    If you are participating in a tax shelter, be sure that it only gives receipts for the price paid for items donated & that charities are achieving a 100% disbursement quota. They DO exist – do your homework!

  18. I wish that you would get your facts straight before you bash this particular tax shelter. In the above example it was not a donation of 10k, that was just the prepaid interest on the full donation amount of 40K. It is no different than donating on a credit card.

  19. Hi Stuart,

    You are mistaken. You are referring to the COIP program, which helps donors use credit to make a donation. This is very different than the
    CHT program, which I mentioned in my last post, and uses a “Gifting Trust” structure, which gives donors something free from a trust & they donate it to charity to get a receipt.

    I think you are simply getting the 2 of them confused, right?

  20. Steve,
    Any comments on the COIP program?

  21. All,

    Does anyone have any comments in regards to the COIP progam?

  22. Hi Anna,

    I personally feel that the COIP program is perhaps the strongest donation tax shelter program in the country, based on a few very important criteria:

    1) No CRA warning of this type of structure
    2) No inflated receipts (i.e. – donation receipt = purchase price of donated goods)
    3) Deflated receipts are present (1st donation is 20% less than FMV “otherwise determined” by appraisers) due to reduction based on purchase price & 2nd receipt is reduced to $0 despite a small cash donation.
    3) No charging any fees to the charities involved (i.e. – charities are perhaps the highest performing charities in Canada due to OVER 100% disbursement quotas)
    4) GAAR inadmissible by law by the presence of SAAP’s – Deflated receipts & interest component not tax deductable.

    Just my opinion…

  23. Steve,
    I agree. I tried to get as much info as possible and every time I call the CRA they never have a straight answer for me other then “do not get involved”. That is unacceptable answer. I will donate this year and hope for the best.
    I truly can not find anything wrong with this program.

    Thanks Steve, greatly appreciate it.


  24. That’s like asking Dracula if he thinks we “really” need our blood or whether we should give it to him…



  25. Hi Steve,

    I got a questionnaire to fill out for CRA in regards to my COIP contribution in 2007. Did anyone receive the same?

  26. Everyone received/will receive the questionnaire from CRA. It’s one of their harassment/fear-inducing techniques. This, along with the attached warning. You just need to deal with it.

    I contributed to COIP in 2006 onward. I completed the same questionnaire afterwards. If you haven’t already received it, COIP will send you a letter or email showing you how to complete it correctly. It’s a bother, but well worth the time.

    Some people who commented above don’t seem to be aware or understand some basic facts regarding tax shelters. First, there are many tax shelters; your RRSP or LIRA are but two of them. Second, what matters is not somebody’s first (usually wrong) impression, but the law. Third, to my knowledge, only one tax shelter has ever been convicted in court. (The buy art low, donate high one.)

    Even with the truly egregious tax shelters, CRA usually comes to some agreement to reduce the benefit at worst.

    In the case of COIP, I believe they’ve followed the law. That’s what matters. Steve above pointed out some of the reasons why this is the case. There are more, so check them out for yourselves.

    CRA’s job is to collect money for the government. They like going after easy targets like individuals rather than the really rich and corporations who have the legal muscle to fight them.

    That’s why COIP’s got a $1 million defence fund built up. They knew the CRA would audit the program. But they also know that the program is on solid footing and thus eminently defendable. I think that CRA knows this too. Now in its fourth year, why hasn’t the CRA done nothing more than levitate boogie men?

    Finally, the government could have made this program truly illegal easily by changing a few things in the law. But it hasn’t. Why not? Maybe it’s because they get praise from the leaders of the countries who’ve benefitted from the AIDS drugs donations even though they’ve been cutting back of foreign aid? I don’t know.

    My only advice is to not depend upon the words of agenda-laden reporters or knee-jerk reactionaries. Take a close look at the details and decide for yourselves.

  27. I agree with Richard.

    It’s important to note that the end result for the Klotz/Nash case which “lost” in court was that the donors receipts were reduced to the price they paid for the artwork – is this a loss? Maybe for the individual’s net cash-on-cash return, but what do you expect if you intend to save your taxes this way? This court decision is what the COIP program was based on: the price you pay = your donation receipt. Klotz & Nash supports the COIP program. The results of that case prove why the COIP program works.


  28. Thanks Richard and Steve…there is a lot of misdirection and falsehood out there. Its nice to have some clarity!

  29. Can anyone tell me how long does CRA have before they can audit me. I have done the program since 2007…I don’t think I will do it this year. When can I stop worrying they won’t come and ask for the money back.

    • Canadian Capitalist

      “Normally, the CRA can only go back three years to reassess a prior-year return. However, if an error or omission was made out of neglect, carelessness or wilful default, the CRA can go back as far as it wishes.”


  30. thanks for the reply…they only have three years to do that. If I did the program in 2007, they have until 2010 to autid and go back as far as they want. Once the 3 years is passed they can’t do an audit or ask for the money.

  31. in reference to the “fight aids save taxes” the promotors of the “COIP” and “MISSION LIFE FINANCIAL” programs check out their websites. when i first heard about these programs i spent two and a half months researching them. the only negative feedback i found were peoples opinions based on fear. yes there are many tax shelters out there that are in my opinion illegal. after all my research i then phoned revenue canada at (1-800-267-2384) charities client assistance. i told them that i wanted to invest in a tax shelter and his responce was “you do not want to get involved, there are too many grey area charities” i then asked about a specific charity. the one that “COIP” uses called THE ORION FOUNDATION tax shelter #119213122 RR0001. he told me they were in the top 1% of charities. they did everything acording to there, mission obligation, when audited a few times per year. “THE TAXMAN SOLD ME ON THE TAX SHELTER”. i bought into the program, and became an ambassador #10219 “fight aids save taxes” if you are interested in saving big time on your canadian personal taxes i can help you with your questions. just e-mail me at bfirbank*no spam* remember when you fill out your income tax return there is just one line to put your donation amount in. with no charity name its your word only. with amounts of $20000. or more dollars the taxman may want to confirm your donation receipt by faxing it to them if they get in touch with you. give me some feedback please!

  32. can someone recommened a good accountant who knows this program…if you do pelase email me at joshi04* no spam*

  33. Have you heard that COIP has been replaced by Mission Life Financial inc. (
    What happened if we get audited by CRA now?
    Can anyone explain?

    • Dear Anna,

      I have been audited for 2011 and 2012 taxation years. We have been ripped off, no doubt about it. The Winnipeg CRA office offered me a deal to drop the donation I claimed ($30,000.00 on $89,000.00 in 2012 and then my taxes would be completed by CRA and I would then be in hock to Revenue Canada for $10K minimum) even after my taxes were all deducted at source.

      Again, Anne, I hope I have answered a part of your question. Despite what you may hear from GLGI or Mission Life or whomever, were are on the hook for the taxes we attempted to dodge through the charitable donations. Still, as someone just said on here, I, too, am not prepared to put my head in the taxman’s noose just yet. Wait and see when all of this goes to Tax Court. A few crooks at the top got wealthy. We were scammed, I’m afraid.

      We may have a faint hope things will go our way, but I doubt it. Sorry for the bad news.


      David, Alberta

  34. Email Steve who works for COIP and see what he says.

  35. Canadian Capitalist

    When donating to charities, doesn’t it sound suspicious off the bat if the charity is willing to issue a receipt for more than the donation? When I donate to a charity, my aim is to help the less fortunate, not make a profit on the donation. IMO, getting more money back from the tax man than the actual donation itself simply doesn’t pass a basic smell test.

  36. Steve,

    do you have any comments?

  37. Does anyone have any comments on how they see the outcome will be for COIP?

  38. I guess Steve is hiding with all our money….I guess you and I will find out the outcome when we get audited.

  39. His silence is intriguing me. Why the silence…..ANYONE????

  40. i would call COIP and ask for Steve…if you need his email and phone number let me kow.

  41. any updates?

  42. Does anyone know how to proceed once CRA send out the reassessment?

  43. not sure as i’m waiting for that as well. They have up to 3 years to reasses you. Hope they don’t sent out a reassessment letter.

  44. Good morning all,
    I briefly spoke to a COIP representative. He explains that if we receive any reassessment for the CRA, NOT TO PAY and send it to COIP immediately. They will take care of it for you.
    The worst case scenario is after 5 to 10 years from now with many discussions with COIP lawyers and CRA. If at the end of the court case..etc..etc.. We lose they will ask us to pay a maximum of 50% of the checks we wrote. No penalties and no fees. I figure if this is the worst case is that bad!
    Can someone please verify with their COIP representative if this is true? I still find it odd that they will come after the money I advance instead of the tax receipt I received…… any thoughts?

  45. I called COIP head office and they told me the following that could happen:
    • WIN at supreme court
    • We lose and we need to reimburse 100% what we received.
    • CRA can’t afford to go to court so we settle on $.30 a dollar…
    One question two total different answers!
    Any thoughts….

  46. Your second comment is true, not the first one. If you don’t pay the reassessment, interest will be billed until the final decision. Worst case, you pay back your refund, all the interest plus penalty.

  47. Actually they say NOT to PAY the reassessment! At the end of the day a decision will have to be made and at that point interest and penalties will be waived even if we have to reimbuse all..

  48. not paying is fine but they will ask for interest and penalty. This is CRA…they won’t let that slide.

  49. Canadian Capitalist

    “CRA can’t afford to go to court so we settle on $.30 a dollar…”

    I somehow doubt this is the case. CRA probably employs an army of lawyers and profitable donation schemes are juicy targets.

    I second Ravi’s opinion. CRA would likely be after for interest and penalty. Anna, did you get reassessed?

  50. Not yet. I donate in 2007 and 2008. What I don’t understand is that I did do my due diligence and they confirmed that there was no warning against COIP. How can they now tell me otherwise? I called the CRA plenty of times asking the same question and I never got a negative feedback.
    I am sure that the CRA will try and ask for interest and penalty BUT I was told by 3 different people at COIP not to pay anything.

  51. Anna, i’m looking for somone to do my taxes. Would you mind emailing me the person you used to

  52. I called CRA this morning and there are no warnings against COIP. They said that they will audit everyone that donates to tax Shelters regardless the shelter that they are in. This doesn’t mean that COIP isn’t complying with the law. COIP does not issue inflated receipts.
    There are 2 other tax shelters that are in discussions with CRA and I am sure that both parties will come to some arrangement. The law is vague and there are loop holes. If the CRA was totally against tax shelters, why do they still allow us taxpayers to donate a maximum of 75% of our salaries?
    I personally think that COIP is a strong organization hence my donation. You should not be afraid of the CRA. We also have rights!

  53. I have just heard about the tax shelter called Missionlife. I have been in the process of researching it. That is how I came across the site; I used the terms ‘scam missionlife’. Both myself and my son are interested the donation component, but I am scepitical about the tax shelter scheme. So please provide more information, as I keep researching. Thank you,

  54. hi all : i have four pages of questions and answers re: MISSION LIFE andCOIP. e-mail me at bfirbank*no spam* with a fax number and will fax to you. in time i will post them here. these TAX SHELTERS, in my opinion the best tax shelters in CANADA for the average person
    now if only we could overcome fear,cynicism,laziness, bad habits, and arrogance we could have fun working towards financial freedom!

    have a great week! brian

    • Canadian Capitalist

      Brian: Why don’t you send it to me via email at cc *no-spam* Personally, I feel that charitable donations are just that — money donated for charity, not money to make a profit on. There are so many ways to make money — making profits on charitable donations is not worth the hassle IMO. I can totally understand why CRA takes a dim view of donation tax shelters.

  55. Has anyone heard from Brian? I emailed him twice.

  56. can you please pdf them and send it to me at THANKS

  57. I am quite curious on the information that Brian’s has.

  58. ANNA: i tried to e-mail the 4 pages to you but they would not go through. Canadian Capitalist please e-mail me your mailing address and i will send you all pertaining information on MISSION LIFE FINANCIAL at, if anyone else wishes more info let me know.

  59. Thanks Brian. I got it :)

  60. Here’s some very good info put out by a lawyer in Ottawa. It pertains to donation programs, .

  61. I noticed the “Canadian Capitalist” mentions a few times that he/she can’t understand how somebody can get a receipt for more than the amount donated, therefore these tax shelter programs must be bad.

    The first part is absolutely correct – you cannot get a receipt for more than the amount of your donation.

    The second part of these statements, however, is where you are missing the key facts – you don’t get a receipt for more than the amount of your donation in any of the better tax shelter programs, and this is why they are exactly in line with the letter & spirit of the law.

    I think where people get confused is the fact that people are FINANCING their donations and only paying interest, etc. up front & have a debt that must be paid back down the road. These programs are actually only tax DEFERRAL programs & not true shelters.

    “Getting a donation receipt for more than what you pay” could equally be applied to people who use their Visa to donate $1000 to charity & then only pay $10/month as the minimum payment.

    The newspaper articles, the CRA, & even people on this forum all scream “Scam – These people are getting inflated receipts! They’re donating $10 to charity & getting a receipt for $1000”

    Get real, people – we’ve grown up. Tax shelters have changed and the old problems don’t apply. Now you can do well by doing good – they’re not exclusive any more. Do your homework on philanthropreneurialism & hybrid philanthropy and don’t believe the hype people give you especially if it doesn’t apply! Just because people can’t understand it, doesn’t mean that there’s a problem with it.

    P.S. – Nimi & Anna – sorry if I didn’t respond to you earlier, but I only visited the site once or twice & made a few comments. Although I enjoy it, I don’t read this blog like the daily newspaper! :)

  62. A note on Anna’s and Ravi’s recent coments about not paying the reassesment… You have 90 days to send an objection or dispute to the reassement. Once you have done this you don’t owe cra anything until the final court ruling between them and the tax shelter at that point you would owe them whatever the ruling was but no interest. It is your legal right to dispute their decision and they can not charge you interest while this dispute process takes place. if you just didn’t pay when you received the reassesment they would charge you interest, send the file to collections, and you would put a ding on your credit score. if you took the money you received back on your tax return and invested it in a secure low risk investment investment even if the judgment forced you to pay back 100% of what you received you would still get to keep the interest that you earned on that money in the 8 – 10 years it took for the whole process to occur.

    some of the wealthiest people in our country use these tools to get even further ahead, we probably can’t afford the type of advisor’s that they have access to so it is up to us to take a cue from them and educate ourselves as much as possible.


  63. B,
    I am assuming that we will give something back But not 100%. It will most likely be an average from 30% to 50%. We have a strong case and even till today the CRA has nothing negative to say about COIP/MissionLife program. In Canada there has not yet been a case that had to reimburse 100% even the buy low sell high art programs came to an agreement

  64. I made the tax shelter donation to ICAN through GLGI in 2006, to Barter World in 2007 and COIP in 2008. While enjoying all the tax savings, i fnally got the audit from CRA on ICAN. The bad part is that CRA suspended ICAN indefinitely in 2007 when ICAN could not provide edequate numbers for CRA’s audit. But my donation was in 2006 to ICAN, so I don’t know if it would make any difference. The letter stated that unless I could provide more backup to support my claim within 60 days, CRA would deny my donation claim. I did exactly what GLGI advised and now it’s over 90 days and I still did not get any response from CRA for denial. I wonder if anyone have similar experience. Thanks for your time.

    • I am confuses. When you guys say you were audited, what do you mean? The full audit of someone reviewing your entire financial history and business personally, or just the letter asking for info on the tax shelter you participated in? Please clarify

  65. Once you file the NOO(notice of objection), the CRA is no longer your administrator; the CRA then becomes the opponent in court. The CRA will select a few cases. Based upon the result of the cases the ruling will apply to all. This can take between 5 to 10 years

  66. Anna. Thanks for your information. What do you mean by “CRA will select a few cases”. So far it’s been more than 3 months and I still haven’t received any denial notice yet. Hope I never will. I still plan to do the donation again on COIP. Seems like this is more reliable organization.

  67. William,
    Please contact Brian at bfirbank*no spam* He will fax you four pages of questions and answers re: MISSION LIFE and COIP. This will answer all your questions. If you don’t get a hold of him please email me.

  68. Anna:
    Thank you. I was busy working two jobs and couldn’t come to this website until today. Thanks for the information. I’ll contact Brian and will go from there.

  69. Hi all,

    I just received the CRA 2008 Questionnaire regarding the COIP tax shelter program.

    Has anyone else received it?

  70. Hello Anna, I have received Questionnaire for 2008 as well. I got the questionnaire for 2007 in February of this year, filled it out and send back to CRA.

  71. I am glad to hear we are the same track. Have you contacted COIP yet?

  72. Yes, the reply was, I quote:
    “Yes we’re aware that our donors have just begun to receive this, we were expecting it. We’ll have a response ready for you within the deadline. The only thing we can not send you is a copy of the cancelled cheques. I suggest you phone your bank and have them send those to you (we only have copies of the front of the cheque before it was deposited). Please contact our office if you have any questions. “

  73. I will contact them tomorrow am.
    What do you think is next?

  74. Hi Anna & Aleksey:

    I received the questionaire last Friday too. A bit nervous about it. How do you guys feel?

  75. Hi William,

    I feel the same. I donated 2007 and 2008. I normally don’t take risks like this BUT I guess time will tell……

  76. Well, I am much more riskier then you guys. But before I invested I found out exactly how the process goes.
    This is what is going to happen next:
    COIP will send you the pre-filled questioner. The only blank space will be to put your own personal information in it. Also they will send a manual explaining what is what.

    Next year you will receive the letter from CRA saying that you donation claim was denied, you have to pay penalty or something in that manner, a lot of bull crap basically. Probably you will freak out after that. You will contact COIP and they will tell you what to do. You will file against CRA’s claim and CRA will back off and that is pretty much it.

  77. You will file an objection, at which case the fun will only begin. After you lose at appeals you can go to tax court.

    Why would anybody buy into something they knew would be tied up for years in the courts?

  78. Hi Aleksey:

    I am prepared to be risky. I provided the CRA with whatevert the information they need and so far they didn’t send me any kind of notice that they would deny my claim. That’s the donation I made in 2006. I hope they will back off. If you said that you are more riskier, did you have the experience already before that you were denied and when you file notice of objection they didn’t respond at all?

  79. Dan:
    Sounds like you are not very much into this kind of tax shelter program. Until CRA clearly states that it’s illegal to do, I am preapred to face the challenge from them. I read a lot from the websites about how people feel about this tax shelter programs and there are many pros and cons and just confulse the hell out of me. However, if I go to the CRA site and read about the tax shelter program, the only thing they say is to make sure that the charity is legitimate and that they have the tax shelter nunbers. They warn the people to be careful in terms of choosing the charity group. in other words, the charity group is the key. If it’s illegal, wouldn’t they just say that we are not suppposed to get involved with this tax shelter program at all? Your opinion is appreciated.

  80. William:
    Well tax shelter numbers really does not really mean anything. They are just numbers for classification.

    Do you have anyone that you know that have lost the objection and had the donation denied?

  81. Hi All,
    I’ve called the CRA back in 2007 and 2008 and a few months ago and they still said that COIP was one of the top charities. They also said that they were audited a few times a year. So if the tax man at CRA tells me this why would they then audit me? And if this was illegal why issue tax shelter numbers? anyone??

  82. Anna:
    Tax shelter numbers are for indification purposes. What is your driver’s license number for?
    Does anyone uses it? No, it is just easier to track by the number

  83. I am not really questioning the tax number, what blows me away is that when i call, they never really say anything other that they have no warning and that they have been audited.
    So why come after me? If its truly illegal why issue the numbers and why not stop it all together like other countries?

  84. COIP seems to be a little different than some of the others. Am I right to assume that you people still owe the donation amount, only it is denominated in some sort of medical units? When do they go after you for the amount?

    Why didn’t you just do something totally legit, like donate securities with capital gains?

  85. I agree with Anna. If CRA really said that they audit COIP few times a year, I have to assume that auditing us the little guys is just a strategy to intimidate us. If we all make this type of tax shelter donation, they would have lost a lot of revenue. Obviously they cannot stop this tax shelter program because technically speaking it is still legal at this time. I think CRA can deny us only if they can find something fishy with COIP. If COIP does their part properly, we should be ok. I really want to hear from someone who’s been denied before and what they intended to do…..

  86. Dan:
    Do you have more information on the donation on securities? I heard something about it before from Bank of Montreal.

  87. Hi Anna:
    On your comments 86, I would assume that you referred “they” as COIP. Am I right? If so, did they say anything that they were able to provide whatever the information CRA requested? This part is important. ICAN got suspended in 2007 because the allocation of donation was not clear in the accounting; hence CRA suspended them indefinitely. Ironically former Prime Minister Jean Chrestien sent a compliment letter to ICAN for their job well done. How ironic.

  88. Canadian Capitalist

    @Steve: I believe you are saying that leveraged cash donations are kosher but CRA says otherwise.

    “It is the CRA’s position that debts incurred as part of a leveraged cash donation constitute limited-recourse debts if they are to be repaid under such arrangements structured as part of the donation arrangement. The donation amount will be reduced accordingly.”

    I reiterate my original comment. Why would anyone want to risk participating in these donation schemes and worry about a CRA audit? It simply doesn’t seem worth the risk to me.

  89. Hi Canadian Capitalist:
    If you think that it’s not worth the risk, do you have any other program to help people saving the tax? After all, we do that for this main reason simply because the government charge us too high of the taxes……

    • Canadian Capitalist

      @William: If you are looking at strictly saving tax, you can make RRSP contributions. You can borrow to invest. You can invest in flow-through limited partnerships. Or Labour-Sponsored Funds. Note that apart from RRSP contributions the others are not without investment risk. But all of them are without any tax risk — there is little chance that CRA will challenge these breaks. Charity donation schemes have both investment (it’s basically a double-or-nothing gamble) and tax risk and are best avoided, IMO.

      Nobody likes to pay taxes but sometimes you have to bite the bullet and cut CRA a cheque. The alternatives may be worse…

  90. William,
    When I asked COIP if the CRA audits went well, COIP replied that they submitted everything that the CRA asked for BUT then when I ask CRA, they do no not release that information.
    All this to say is that I expect to repay some back in about 5-8 yrs. As per my research with friends that donated to other programs some settle to pay back 40% with no interest and no penalty. BUT we should not settle and wait till the end..
    What other programs are out there that can help save taxes??

  91. Anna:
    I made donation in 2007 to the charity called “Barter World”. The donation is almost like COIP with the loan to borrow and loan proceed to make donation. CRA did audit to their charity and somehow Barter World was able to settle everything with CRA, so whoever made the donations that year to Barter World would not be audited by CRA.

  92. That’s great BUT it’s not the case with COIP. I received an 11 page letter from the CRA explaining why COIP is not being considered as an eligible tax shelter. I think this is routine for them. I am calling COIP this afternoon.
    Have any of you received this?

  93. Anna:
    This one doesn’t sound good. Why would all of a sudden that COIP is not being considered as an eligible tax shelter when CRA stated before that they are one of the better ones around?
    When did you receive this 11 page letter?

  94. I received it last friday, COIP is putting together a package so all donors can respond. Apparently this is a standard procedure with the CRA.. COIP needs more time to respond so I am sending the CRA a letter of extension that COIP sent me. Lets the games begin…. What baffles me is that there is no warning against COIP yet they still send me a letter telling me that all donations have been denied..WTF!

  95. They are denied every year automatically by the CRA. Then COIP is fighting back and so far won all of them.

  96. Anna & Aleksey:

    I also heard that even though some people got denied and they returned the money to CRA, the doners would get a form from CRA stating that if they wanted the money back, they were required to fill in that form and the money would be returned to the donors while the dispute was still on going.

    I’ll try to get my representative and see if she has that copy of the letter from CRA.

  97. I have no intentions of returning any money until the CRA conveniences me that COIP did not comply with the laws. Once I send the NOO (Notice of Objection). I don’t owe CRA anything until the final court ruling between them and the tax shelter. This is what my COIP representative told me .

  98. Anna:
    You’re right about that one. I just don’t understand this. If it’s illegal, CRA can immediately deny the whole thing instead of sending us the money and then do audit. Don’t you think that it’s a waste of everyone’s time? If tax shelter program is illegal, then make it totally illegal, so we won’t get involved with it then. I just made some donation today for the 2009 taxation year. The amount is smaller than last year, but I still have a bit on the side and see if other opportunities available other than tax shelter. If not, I’ll donate more before the year end.

  99. William: your 2006 participation in COIP, has the second loan been paid off yet? Your 2007 participation in Barter World, you mentioned that they settled with CRA, on what amount?

  100. Hi Alnaexan:

    I participated ICAN through GLGI in 2006, Barter World in 2007 and COIP in 2008. CRA suspended ICAN in 2007 for their inability to provide proper accounting numbers to support the donation amount for the year 2007. I am not sure if I’m safe for 2006, as I don’t think ICAN had problem with CRA that year. As for Barter World in 2007, they had some kind of settlement with CRA, so the donors won’t get the audit by CRA. I don’t know the amount Barter World settled with CRA. I am trying to get that letter from my representative about this. As for 2008, I participated the tax shelter program through COIP and you probably know that it’s done by way of loan, so the donation amount matches to the T5003 instead of inflated value by appraisal. I think the set up is instead of paying the whole loan proceed, we are to pay interest (initial amount to lender) and the proceed to be paid by way of purchasing drugs by wholesale price, which is significantly lower than the retail value. Do you have a different interpretation of COIP program? Your comments is appreciated.

  101. I donated money in 2008 to COIP but I did not claim them when i did my taxes but they still sent me the questionaire to fill out. Do I still need to send in the questionaire eventhough I did not claim it on my 2008 tax return.

  102. Canadian Capitalist

    @Anna, @William: If you don’t mind me asking, how much was your cash donation? What was the amount of the tax receipt? And how much is the CRA asking in penalties and interest? Others can also

  103. Canadian Capitalist:
    for 2007 I made $7,000 with T5003 for $35,000. CRA did not ask for penalites or interest at all at this time.

  104. Ravi:
    I’m wondering why you still got the questionaire from CRA. If I were you, I would contact CRA first as to why you have to submit or if you need to submit the questionaires when you didn’t even claim it. Was it a big amount of tax receipt you got? What was the reason why you did’t claim?

  105. i was scared and i did another way of doing my taxes. The receipt was for $28K. COIP said they submitted everyone name who did the program so that’s why CRA sent me the questionaire. I don’t want to call because then they will know who I am, etc. Please help

  106. Ravi:
    You should be ok because you didn’t claim it. If I were you, I would just inform CRA and told them that despite of your contribution with a receipt of $28k, you did not claim, hence you do not have to answer their questionaire.

  107. Ravi,

    I would not call them BUT send them a letter stating that you have no such clam on your income tax. This goes to show how unorganized they are…pretty scary..

  108. Ravi:
    Anna’s idea is ok too, if you don’t want to talk to them on the phone. Just send them the letter, stating that you don’t hvae such claim; hence don’t need to answer those questionaires. It’s amazing that they don’t even know that you don’t have the claim in the filing. Unoragnized is even understatement.

  109. @ Canadian Capitalist

    Sorry for the delayed response. COIP or MLF are not leveraged cash programs. If you read the details on the link you suggested: you will see that a leveraged cash program involves a loan of cash that is donated to charity.

    It appears that you still don’t have a clear understanding of how these programs work as I’ve seen you asking many of the bloggers how much cash they donated & what receipt they received.

    Donors in COIP & Mission Life do NOT donate cash to charities as their main donation, they donate MEDICINE, which they purchase. There is no loan of cash, which is what a “leveraged CASH” program is all about. This type of program died shortly after the buy low/donate high programs and haven’t been done since as the CRA warns about them (along with Trust arrangements) Coincidentally, they still do NOT warn against buying something on credit terms & donating it to charity, which is what COIP & MLF do.

    There actually IS a small cash donation (i.e. – $200 in cash per $8000 worth of medicine donated) and the donor receives a receipt for $0 or a reduced amount compared to the cash. Isn’t that neat – a DEFLATED receipt from the charity. The CRA should rather people participate in these programs v.s. doing the same thing outside of the structure as they are giving LESS taxes back. Interesting, eh?

    People – the whole concept of a “profitable gift” is perfectly fine as long as it’s not done with the charities providing funky receipts. These are all “gifts in kind”, not cash donations (for the main donation) & the donors cost of the item donated has to equal the amount on their receipt. How the person finances their purchase that they donated has nothing to do with the amount of the receipt. If that were the case, then somebody who borrows $1000 to donate to charity & doesn’t pay their
    debt back for 5 yrs would be forced to receive a $0 receipt as it actually did NOT cost them a penny at the time of the donation!

    I hope this is starting to sink in for some people…



  110. Canadian Capitalist

    @Steve: I hope you’ll make clear if you have any affiliation with the donation programs you mention.

    It is your opinion that the donation programs mentioned are NOT leveraged schemes. In my opinion, they clearly qualify as “limited recourse debts”. Credit card debt is not limited recourse — the only way to get out of it is to repay the loan with all interest due. I guess we’ll find out what view CRA takes of these donation shelters.

  111. Hi Steve:
    Your coments (113) is very interesting. I received the audit questions from CRA on COIP donation I made. COIP also sent me the answers for review. However, there are few questions that printed in green have to be answered by ourselves. They did not provide the answers. These aret the questions related to the loan program (1st loan and 2nd loan). Do you have any suggestions as to how to answer these questions? I’d like to know the link site that can help me on this or if you can help me. I don’t want to answer incorrectly so as to allow CRA to nail me. Your help woudl be greatly apprreciated. Thanks.

  112. Please see above my comments (115) to Steve. Anyone else who can help me would be greatly appreciated. Thank you very much.

  113. @ Canadian Capitalist

    Canadian Capitalist – it’s not my opinion that any tax shelter program running in Canada now is not a leveraged cash program. It is a fact.

    If you read carefully from your first comments, you use the term “leveraged CASH”. I replied that all of the new programs are not leveraged CASH programs and that they are warned against by the CRA. They are not done anymore.

    Now you say that it my opinion that these new programs are not “leveraged schemes”. This is completely different wording on your part.

    The CRA warns against leveraged cash programs. They do not warn against leveraged scheme programs (your terminology).

    #14 on the Taxpayers Bill of Rights states that Canadians can expect the CRA to “warn of questionable tax schemes in a timely manner”. They warn against 3 types of structures:

    1) Gifting Trust Arrangements
    2) Leveraged Cash programs
    3) Buy low/donate high programs

    No warning of your term of leveraged schemes. Any program where you borrow to donate is a leveraged scheme. If you borrow to put into your RRSP you are participating in a leveraged scheme.

    In order to discuss these very important legal tax issues on this forum, I think it is important to use correct terminology so as to convey the proper laws to the readers. You can’t use layman’s terms loosley & try to apply them after the fact.
    We have to listen to the CRA here as they are the ones who do the proper warnings and they do not warn against borrowing to donate.

    My wife, my mother, my brother, my cousins, my uncles, & many friends & family have been participating in the aforementioned programs every year for the last 4 years. We participate with our heads up & our eyes open. We choose to look at what the law says & not what people “think” they know based on incorrect information.

    The CRA gives Tax Shelter ID#’s to allow companies to operate & people to participate, but they refuse to say whether they think the program follows the tax law as to do so would be suicide. If there is a problem with a tax avoidence program (which is perfectly legal to do, btw) and they say where they feel the problems lie, then they give people the roadmap to fix it. If they say they feel it works, then everybody in Canada would do it without fear & the country would lose too many tax dollars.

    I suppose the CRA feels it is too difficult or impossible to change the law if they feel there is a problem, so I guess they really have no choice but to audit & reassess everybody who participates in ANY tax shelter – good or bad. When this happens, it doesn’t really matter if the tax shelter actually works or not as the hassle is just too much for most people.

    My mother is 68 years old & she sleeps well at night after participating year after year as she knows the parameters & the law. There has only been 1 tax shelter arrangement that I know of that has actually “lost” in court after the audit & reassessment – Klotz & Nash. The reason I say “lost” is that the court found that the taxpayer’s receipt should be reduced to the amount the donor actually paid for the art, instead of the higher price they claimed as the “value”.

    Cost = receipt amount.

    It is exactly that premise that all the new programs are based on.

    Canadian Capitalist – you said to me that, “It is your opinion that the donation programs mentioned are NOT leveraged schemes. In my opinion, they clearly qualify as “limited recourse debts”. Credit card debt is not limited recourse — the only way to get out of it is to repay the loan with all interest due.”

    First of all you refer to a “leveraged scheme” and then you imply that these programs are not leveraged schemes because they qualify as a “limited recourse debt”. First of all, we were discussing what the CRA warns against on their web site, which is a “leveraged CASH” program vs. your term of a “leveraged scheme”.

    To put that one to bed – cash has to be lent & then a portion of it invested in a plan to grow the money to pay off the debt. This is not present anywhere in Canada anymore as the guarantee of the investment constituted a limited recourse debt as there cannot be a “guarantee or covenant” that the debt will be repayed without full recourse to the borrower.

    Now, if you are comfortable with the proof above that leveraged cash programs are no longer offered, we can move to the new programs, where I think I see where you were trying to make the connection.

    You feel there is a limited recourse debt (nothing to do with a leveraged cash program) and feel that a credit card transaction is different because “the only way to get out of it is to repay the loan with all interest due”.

    If I understand you correctly, then you are saying IF the programs in discussion were to have people repay the loan with all interest due, then you would concede that it is okay – just like using a credit card is okay.

    Perfect. That’s exactly how they work. Case closed. We’re on the same page.

    The fact that you didn’t know this goes waaaaay back to my original thread where you don’t know how the program works!


    Please find someone to show you how these new programs work so you can see the interest paid, the debt repayment in full, etc. They are NOT even tax shelters – they are tax deferrals.

    You mean to tell me that you didn’t even know that the thousands of participants have a big debt to pay back in the future? You didn’t know that they haven’t even finished paying off their debt yet?

    Canadian Capitalist, it would really be best if you actually see how these programs work BEFORE making statements about them. It’s simply not prudent.

    Please understand – you seem like a very nice person & I know you are trying to help people on this forum, but when I’m talking about one thing & you are discussing something completely different because you simply don’t know or haven’t checked it out fully, it makes it frustrating for me & impossible for people on this forum to get the right answers.

    Let me know if you would like me to arrange to have somebody from one of these companies give you a presentation – I guarantee you will come back on this forum & say things that will actually be based on real knowledge. I guarantee that you will at least have a complete understanding of everything.

    With good intent,

    P.S. – I am not a principle, nor have been a principle, of any tax shelter company that has or is presently operating, but I do refer people to the better programs.

  114. P.S. – We already know the “view” the CRA will take of these shelters – they will challenge everybody who participates! That’s what they do. That’s also why it is NOT a reason on which to decide if a program follows the law or not or whether you should participate.

  115. Canadian Capitalist

    @Steve: Thanks for clarifying that you are not a principle in any tax shelter. But the intent of my original question was: Do you receive compensation for “referring” people to the “better” programs?

    “If I understand you correctly, then you are saying IF the programs in discussion were to have people repay the loan with all interest due, then you would concede that it is okay – just like using a credit card is okay.”

    I’m not conceding anything of the kind. There are two parts: (1) the charity must be legitimate (not simply be registered with CRA; most of the donations should go towards charitable causes) and (2) If the money is borrowed for the donation, there must be a clear requirement that the principal and interest owing must be repaid. Borrowing from a credit card or line of credit satisfies (2) because failure to repay has dire consequences. The credit card company does not care about (1). It is the donor’s responsibility to make sure she is picking a legitimate charity.

    You contend that these new schemes satisfy (2). You are saying that participants in these new types of charity schemes have a big debt to coming due in the future. Here’s my question: Does this loan show up on their credit report? How do these programs make sure that they collect the loan? How are these loans made in the first place? Do they run a credit check and charge different interest rates for different risk profiles? Are they secured against property of some kind?

    You can argue till you are blue in the face that all these schemes are perfectly legal. CRA might take a different view. My bottom line is the same: if it’s questionable, why get involved?

  116. @ Canadian Capitalist

    Now you are talking about 2 new elements. I’m answering each concern concisely & you are rebuting with new problems. Each area is a different one to address.

    Now you’re talking about legitimate charities, most of the donation going to a charitable cause, & clear requirement that the debt must be repaid.

    Once again – in all of the new programs MONEY IS NOT BEING DONATED. I don’t know how many times I have to tell you this before it sinks in.

    If you are concerned about charitable works, then you should absolutely love these programs as 100% of the donation goes to the actual charitable works and the charities have an OVER 100% disbursement quota. I know you may not know what the latter means, but it’s the reflection of received donations to charity v.s. what they receipt for the received goods.

    Charities in the newer programs receive goods from the donors, not cash. Physical, touch them, heavy to carry, gifts-in-kind items. Yes, you can do that. Yes, it’s legal. Yes, that’s how these programs work. Please do not refer to these programs as donating cash again – it’s simply false.

    Because people are buying AIDS medicine & giving the physical goods to charity, the charity CANNOT misappropriate those goods or misspend the donation on booze or cigarettes, right? Because it’s buckets of life-saving pills, only people with AIDS can really use them & Canada does not have an AIDS epidemic, so there’s no black market for the charity to resell the pills. 100% of them go to dying people in Africa #1) because the charities have forensic audits which have been supplied to the CRA at their request to prove this has been done & #2) it just doesn’t make sense for the charity to keep them!

    There are 4 parts that dictate whether a debt is limited recourse or full recourse:

    1) The debt must be paid back in 10 yrs
    2) The debt must bear an interest rate charge that is not less than the government’s prescribed amount at the time it is taken out
    3) Interest on the debt must be paid not longer than 60 days after the end of the each year
    4) There can be no covenant, guarantee, or indeminity to forgive the debt (i.e. – the debtee must have the full legal right to come after the debtor if the debtor defaults)

    According to the law, a credit check does not have to take place – only the 4 things above.

    This is further evidenced by the fact that I can borrow $100 from you, use it to buy $100 worth of AIDS pills, donate it to charity & receive a receipt for $100. The law does not require you to do a credit check on me to ensure the loan is “real”, only that I pay you in accordance with the 4 rules above.

    The law does not discriminate against people who have poor credit who want to donate to charity.

    Failure to pay having “dire consequences” with regards to donations is not a legal term, nor has any legal bearing. But, if you do feel that it is necessary from a moral standpoint, then I’m sure you would concede that a lawsuit for tens of thousands or hundreds of thousands of dollars would be more “dire” than a black mark on your credit score by Visa, right? Once again, if we go by your requirements (which are not based in law) then we’re covered as there will be much worse dire consequences if anybody defaults on their loans – just wait & see.

    Regarding your statement that it’s not enough that the charity be registered with the CRA – legally,you are wrong when it comes to the validity of the tax receipt as this is actually the ONLY thing that matters when donating to charity for tax purposes.

    Now, if you are meaning morally & ethically, then yes, I agree with you and once again that is why charities with higher disbursement quotas prove that they are meeting their charitable mandate better than other charities (i.e. – more donations are reaching the cause rather than going towards admin, etc.).

    Based on your own wishes & determining factors, you mentioned above, you actually prefer the charities involved with these new programs as they exceed all of your expectations. Simply check out their T30-10’s. (i.e. – the charity’s tax return, which proves it as plain as day)

    Regarding your last statement, “You can argue till you are blue in the face that all these schemes are perfectly legal. CRA might take a different view. My bottom line is the same: if it’s questionable, why get involved?”

    I agree that is a personal decision for each person. I do NOT think that tax shelters are for most people, only about 20% of the population (my guess). Tax shelters which are based in law should only be participated in by people who feel the law is what matters in Canada over and above the CRA. Because the CRA forces this situation on the taxpayer simply because they are trying to save taxes (which is our right by law as Canadian citizens otherwise Tax shelters would simply not be allowed & the CRA would not issue tax shelter identification numbers), that should not be a reason not to try & save taxes if the program follows the law.

    What evidence have you received from a court that ANY of these programs do not work according to the law? I have received none. Please give me a court precedent, a policy in the income tax act or a provision in the income tax act that says so. Nobody in Canada has been able to, so what makes you think it will happen? Certainly the CRA has not proven this in a court of law.

    If all legal costs are paid for & nobody in Canada has found a problem IN LAW with these programs (the only thing that matters from a legal standpoint & we’ve already covered the moral context), then CRA’s feelings on the matter to me are inconsequential. They can’t throw people in jail & they have to follow the law whether they like it or not (they don’t!).

    So, yes, if you feel that the CRA runs the show here in Canada & you can’t think logically & you are fearful because you do not know your rights & you feel Canada is like Nazi Germany, then PLEASE DO NOT PARTICIPATE in any of these programs. You will be saving us valuable reading time on these forums.

    If you feel confident in the law & you know your rights & you have checked out the charity’s T30-10’s and you pay back your debt in full accordance with the law, then by all means – participate if you wish.


  117. P.S. – I do not receive commission for referring people to these programs.

  118. P.P.S. – I just realized why you were asking about commissions! Don’t worry, there are NO fundraising fees charged by the tax shelter companies to the charity. This would not work as the charity is not receiving cash donations (only medicine), so they couldn’t afford to pay any fees anyway.

    People in these programs earn money from the companies who sell the pills – the only for-profit entities in the mix. Think of it like the salesperson working at Futureshop where somebody buys a TV to donate to the Salvation Army. The person who sold the TV got paid their commission for the sale.

    Again, fundraising fees to the promotors of tax shelters is an antiquated system that has been abolished with the new programs. They simply don’t need to work that way anymore.

  119. @ Ravi:

    The reason you got the questionnaire is because your SIN has been linked to the tax shelter ID#. What are you afraid of? You should fill out the questionnaire and return it to CRA. You did not claim the donation credit for that year and carried it forward. What can CRA do to you, other than deny you the donation credit. They can’t apply interest or penalties since you did not claim the credit. 100% of nothing is still nothing. Don’t lose sleep over it.

    @ William:

    Please share the outcome of the Barter World settlement. How many ways can you skin a cat? I think Steve has done a great job of explaining how the program works.

    The questions in green tend to relate to how you filed your taxes. As such the person who prepared your tax return would be the best person to help you answer those questions. If you are still not able to get it done, post email where you can be reached and I’ll see if I can help.

    Remember we are governed by the rule of law. CRA will interpret the ITA in what ever way that benefits them, the same goes for the taxpayers. It is not the person who understands the law the best that will win, it is the one who best prepares their case.

  120. Canadian Capitalist

    @Steve: We’ll see what view CRA takes of some of these tax shelters. Personally, there are so many ways to make money. IMO, participating in dodgy charity schemes isn’t it. And I don’t take the view that CRA is some sort of Gestapo. I personally agree with their view that charity schemes are an abuse of the tax system.

  121. Alnaexan:
    I would appreciate it if you could provide me some ideas of how to answer these questions in green. I would assume that you know these questions too if you participated the COIP program. My email you can contact me is I am the one filing the taxes myself, but I really don’t know how to answer these questions. Your help would be very much appreciated.
    I’ll find out more information on Barter World and will let you guys know. Thank you again in advance Alnaexan.

  122. Any “charity” where you are getting more back than you should is questionable. CRA can and will go after this.

  123. Also, the deceptive COIP information site tells you to take out a loan for the amount, and seemingly refinance it perpetually. So, off a 6700 dollar donation, you’re only really getting the 46% credit based on it’s numbers.

    They use deception to try and trick those who aren’t reading it carefully.

    What screams bs to me is that they want you to finance the loan through them, it seems. So they’re taking your money for the donation, as well as taking your interest money, and pretending to be a charity.

  124. @ Canadian Capitalist & Common Sense

    This is where your problems lie.

    That is not how the COIP program works. COIP has never pretended to be a charity. They sell medicine to people who donate it to charity. The charities are completely different entities. Didn’t either of you read my earlier blogs?

    I agree with Common Sense – any “charity” where you are getting back more than you should is not only questionable – it’s against the law!

    Again – the COIP program works EXACTLY like a Visa card – IT’S A TAX DEFERRAL PROGRAM, NOT A TAX SHELTER. They have to get a tax shelter ID # regardless because the CRA forces every program regardless of structure to register or face $5000/donor penalties.

    Common Sense – you ONLY get a tax deduction for the amount you paid for the medicine. What you are missing big time is the fact that COIP is not a charity & you are paying COIP off over time & not right away.

    Based on your flawed logic & gross misunderstanding of this program, you are saying that if somebody donates $1000 on their Visa card and gets a tax deduction for 46% ($460) immediately then they are participating in something “dodgy” if they haven’t paid off their Visa as they got more than they “put in”. Ridiculous.

    Canadian Capitalist – again, you refer to the CRA’s “takes on some of these shelters”. Of course they don’t like any of them! That’s my point. They can’t like any of them. My point is that there are NOT many ways to save taxes in Canada, that tax avoidence is perfectly legal by law and you know it. Where we differ is on the point that you say you will not do anything that the CRA has yet to prove in court nor warns against (that’s right, the CRA does NOT warn against the COIP structure in any way shape or form) due to what you read about in the newspapers and I base my decisions on what the law says. To each his own. Good luck with your financial future & please share with the rest of us “common folk” all of the great tax strategies out there. BTW – we already know about the other tax shelter out there called the TFSA. It’s really great.

    You two have failed to read or chosen to ignore my accurate information and keep reiterating stuff that is not at all true. COIP a charity? Come on – please show me where COIP is registered with the CRA as a charity. Surprise – it’s not.

    Ask yourself a quesiton – if the law is so clear in your mind that these programs simply can’t work, then why are they still operating? I suppose you feel that our government is powerless to do anything. I’ve got news for you – they haven’t done anything because they can’t as tax deferrals are perfectly legal.

    Guys, it’s been fun, but I can’t keep coming back here to tell you that your understanding of these programs is innaccurate and to tell you over & over that I agree that the CRA will challenge ALL of them. It’s been said over & over.

    I wish you the best in your financial/tax lives and I beg you to NOT participate in any government registered tax shelters EVER. You will be doing yourself a favour.



  125. On November 17th, the Tax Court of Canada ruled on Marechaux v. the Queen – a leveraged donation scheme from the early 2000’s.

    The court nixed the scheme and ordered Marechaux to pay the costs of the legal battle.

    The legal basis for the conclusion is that the taxpayer did not make a charitable “gift” because he received a benefit in the form of an attractive financing arrangement. While the specific details are somewhat different, Steve’s “tax deferral” program creates a debt owed to COIP that I’m not sure how you ever pay off. If you don’t pay it off, that sure sounds like a “benefit” which would disallow the medicine that you donate as a “gift”. If you do pay it off, it is hard to see how you have gained anything from the whole exercise.

    There was no issue of whether it was a leveraged cash scheme or a leveraged something else scheme. the court also commented that it was wise that the taxpayer didn’t argue that he should get a donation receipt for at least his cash contribution portion because it was part of a large transaction that cannot be broken into pieces arbitrarily. (In other words, don’t bank on getting at least a partial tax receipt even if you eventually lose the court case.)

    For anyone who wants to take the time to read the actual decision, I googled marechaux v. the queen and the charity law site had links to the actual decision.

    There are a number of other legal arguments that were not used in this case which may also be available in future court cases so please don’t think that this is the last argument for the crown to use.

    Thank you, Canadian Capitalist, for trying to help people from being taken advantage of.

    The court has said to make your charitable contributions for charitable purposes rather than to get a benefit for yourself. Banking on long delays, possible future settlements at 30cents on the dollar, waivers of interest and penalties is foolish. If you don’t like paying taxes, invest in an RRSP or some other above-board option. Playing games with the tax system is probably going to leave you with a bad feeling in your stomach and quite a few dollars poorer.

    And Steve, you said you weren’t a principal and you also said that you didn’t get paid commissions recommending these kinds of schemes. You didn’t answer whether you were an employee (for example, the vice-president of marketing).

  126. Canadian Capitalist

    @Scott: Thank you for the Marechaux v. The Queen case. It is a fascinating verdict that did not even test the GAAR rule. So, it could take up to 8 long years for these things to be decided and participants in donation schemes have to wonder about the penalties, interest and court costs. Wow!

    Apparently, the scheme was pitched with a tax opinion that the risk of a challenge by the CRA was “slim”. Sound familiar?

  127. Yes, it sounds very familiar.

    I attended a Missionlife presentation a couple of months ago to confront them about this tax scheme they were promoting. I wasn’t impressed with their newspaper ad suggesting that the government and big banks were in a conspiracy to keep people poor and that they would be telling you about things that their accountant wouldn’t/couldn’t.

    Let’s see, listen to the smooth talking salesman in the expensive suit who makes money from getting you to buy what he is selling, or listen to the trained professional with a code of ethics who has no financial interest in having an opinion in one particular direction or another? Tough call.

    But boy they were smooth – they probably learned their presentation skills selling Sham-wow. I wonder if Darren Weeks, the presenter, should start referring to himself as the “Sham-Rich Dad” instead of just the “Canadian Rich Dad”?

  128. I didn’t come back here to continue with any of the previous threads, but simply wanted to show everybody an interesting article in Money Sense Magazine.

    Just so everybody has can see the power of gift-in-kind donations and how proper donation tax shelters promote huge philanthropy with $0 going to the companies and 100% going to the charities (unlike every other tax shelter program in the past), take a look at how one of these companies has single-handedly propelled their recepient charity to the #2 spot in Canada.

    This article in the December issue of Money Sense Magazine used data compiled from our own CRA.

    The disbursement quotas of these charities speak for themselves. The facts & the law are indisputable. This is to prove to you that in all of the newer programs, there are REAL charities who receive REAL goods that people buy & donate. Exact same program as Mission Life, by the way. You will see the charities working with that “Sham” become the best performing charities in Canada very soon – it can’t be helped. It’s the nature of the program.

    Now, before I get swamped with more notes about how it doesn’t matter & that the CRA hates us all and how everybody will be in trouble for participating in tax shelters regardless of whether they are real & follow the law…


    I just wanted to show you one small reason why they are the real deal & should win in court down the road after all the huff.

    Wishing you all a Happy Holiday!

  129. Thanks Steve,

    Happy Holidays :)

  130. Thank you Steve.

  131. HEDAC

    Registered as a charity in 2007, no revenue, no directors listed.
    In 2008, it supposedly brings in $60,691,943
    Most of it it sent outside Canada $58,743,500

    However, bringing in $60 million, doesn’t mean they actually got that money.
    It means they issued receipts for $60 million. Since most of it went outside Canada, or it was gifted to another charity, it’s difficult to determine if they actually ever had $60 million. Is it possible they issued receipts in return for the $444,696 they received in fund raising revenue? Who got the $ 1,516,066 in professional and consulting fees?

    Its humble website hides the fact that it is one of Canada’s 40 BIGGEST
    charities. No glitzy pictures of philanthropic executives. No faces, or names.

  132. The article just came out in December’s Money Sense Magazine, but even if they had more time, I don’t think it would be their goal to splash that all over their web site. They don’t get their donations “off the street” like other charities.

    They did NOT RECEIVE CASH for 99.9% of their receipted donations, so no cash could be misappropriated. They received medicine which was purchased & donated to them. All the data and undisputable proof comes directly from the CRA’s own stats & audits, so it’s 100% correct. We’re talking about DISBURSEMENT QUOTAS here, so don’t get confused about what comes in the door to the charity – it’s all about the ratio of what comes in v.s. what goes out & this charity sends the 2nd highest % of donations out in Canada.

    Yes, I agree with you that it is refreshing not to see pictures of flashy philanthropic executives – this charity is for real and it achieved the 2nd best disbursement quota in Canada through receiving gifts in kind & NOT CASH. In fact, that is the only way they COULD achieve it. And it was achieved almost entirely through the efforts of a company that had to register itself as a Tax Shelter with the CRA. Talk about ironic…

  133. This may all end up being legal due to loopholes in tax laws. Its a complex scheme with registered charities, travelling salesman and off-shore investment companies. Its pretty tough for CRA to prove or disprove the existance of drug “credit units” held in a private investment company based out of Costa Rica.

    But lets be honest about this people, legal or not, your buying bogus receipts to save on your taxes.

    There is no charity, just profit. After your entry fees have been divied up to cover airfare, venues, dinners, salaries, loan fees, commisions etc. Do the math. It doesn’t add up. There’s not much left over to go to charity.

    Consider that you might be buying your receipt from a pimp.
    PIMP: a man who solicits for a prostitute or brothel and lives off the earnings–sex-and-charity-james-arion-profits-from-both

    COIP is not a charity. It is a company formed to act as a fundraiser for charities. They are the travelling saleman. At the end of the day, they can claim they didn’t really know what was going on in the charity. They didn’t break the law, they didn’t issue the reciepts.

    You got no recourse against them as they have told you from the begining that this may not be accepted. When you get legal forms from CRA, they say “No problem, send them to us” You have no idea if your legal issue has been resolved. I would take them to an independant lawyer.

    When it falls apart, all you got from HEDAC is a reciept that you can’t back up with a cancelled cheque, and a phone number that doesn’t even reverse lookup. When you go look for that phone number, you may find the website is gone, just like the Orion Foundation’s.

    COIP? Well it looks like they are trying to disappear too. Its now Mission Life Financial. The charity is now ACTLAP. The names have all changed, but the deal looks pretty much the same. A Glossy brochure of smiling kids in Africa. Doesn’t it just warm your heart to know your doing so much good. And you get a TAX rebate too WOO HOO!

  134. Skeptical, with all due respect. I don’t think you know how these programs work. There’s no money being donated as the main donation, my friend. COIP & the other companies are NOT charities & that “Pimp” guy’s charity has never had any problems with the CRA. They are still registered in perfect standing and have amazing disbursement quotas too.

    I think you may have fallen into the trap of seeing (& believing) things that have no bearing on the law or the charity being done.

    Receipts can’t be “bought”. If they did, the charity would be shut down, not featured in Money Sense. I know this because the COIP & RLG charities are the ONLY charities from ANY of the tax shelter programs of the last decade that have NOT been shut down. Think about it. You’re missing something.

    You should have gotten a receipt from HEDAC and you can easily back that up as you DO make a donation of cash to that charity. Cancelled check backs it up easily.

    COIP, RLG, & Mission Life are all still around & are not disappearing. They may not offer programs in future years because after the programs are reassessed (even though all participants know & expect this) by the CRA, it makes them harder to market. Victory for the CRA on this one.

    All this being said, even good donation tax shelters are not for everyone, so I completely understand why you don’t feel comfortable, but for many people they make sense if you know the law and you can stick to it when rationalizing the programs & the series of events that follows after participating. It really is the ONLY thing that matters.

  135. Just because a charity is still registered, doesn’t mean there are no problems with the CRA. The CRA will not tell you who they are investigating until they are revoked.

    I understand it. This is all completely legal. COIP told you from the beginning that your claim may be rejected. They showed your the CRA warning. They told you to have it reviewed by a lawyer or accountant. They said you might have to pay the money back. COIP is covered legally.

    The claimant should be ok too, up until a time that CRA deccides to do something about it. Might never happen due to the backlog of cases this has created.
    Its all legal until the claim is rejected and you don’t want to pay the money back.

  136. 100% right. Finally, somebody who really “get’s it”!


    It’s cool to know, however, that the stats used to formulate the charity ranking did not come from the charities. It came from the CRA. So, if there is something wrong being done by the charity, they are hiding it very well. Forensic audits done by the CRA simply don’t lie.

    P.S. – Even if the claim is rejected, you still do not have to pay any taxes the CRA feels you owe. This is where most people fail in their understanding. I’m not suggesting you are one of them, but it’s important to remember that a simple NOO will put things to court & as long as somebody else is paying the court fees, then it’s only what a judge says that matters. THEN, if you don’t pay (assuming you don’t take a deal from the CRA before hand and actually lose in court after 1 or 2 appeals) you can get in trouble. By the same token, if you decide to pay the CRA the disputed amount and THEY lose in court, then they have to pay you plus interest, etc. and can get in trouble if they don’t. But I’m sure you already know this. :)

  137. No, you don’t have to pay, you can appeal. The promoters want to brush this part off as no big deal. “No Problem! We THINK your going to win.” At the end of the day, they don’t care if you win. That’s your problem! They’ll move onto the next customer.

    Anyone I’ve ever talked that has been raked over the coals by CRA considers it a stressful and financially painful experience. It is a fight to the bitter end.

    The promoters, on the other hand, are making millions.–daw-suit-claims-charity-sham-misled-taxpayers

  138. Canadian Capitalist

    @Skeptical: I completely agree with you. The simple fact that a donor can make what amounts to a $1,000 out-of-pocket “donation” and get $1,500 or whatever back from the CRA doesn’t pass the sniff test. Steve will tell us that he isn’t affiliated in any way with any of these donation schemes and then upload a MoneySense clip to Relief Lending Group website.

    “The promoters want to brush this part off as no big deal. “No Problem! We THINK your going to win.” At the end of the day, they don’t care if you win. That’s your problem! They’ll move onto the next customer.”

    I do wish that potential donors to questionable charitable schemes will pay heed to this. Sadly, greed blinds many to the obvious risks in these schemes.

  139. Gents,
    No question over the years there has been many questionable tax reduction schemes. I have been considering the Mission Life/COIP shelter. Tax shelters are allowed under Canadian Law and at first “sniff” this seems to comply with the law. That said CRA will no doubt have a go. An over riding theme in this forum seems to be the belief that CRA make tax law. They do not, although they do feel they have that right. CRA simply administers the tax act. The government makes the law, the courts interpret it, the CRA administers it. CRA likes to put out “interpretation bulletins” Ironically these interpretations may be completely different, on the same subject depending on the regional office that put it out. I have in fact won a victory (admittedly on a small amount) when I pointed out an interpretation that differed from a different region. It is interesting (sad actually) that CRA auditors are paid a bonus on “extra” money they collect. In other words they are motivated to wring the most they can out of us, by using these interpretations and refering to them as “the Law” They send letters demanding payment adding huge intrest and penelty charges in the hopes you cave and pay. You only have to look at earlier posts to see the fear and worry.
    Now I’m not promoting this COIP or any other shelter but the attitude of.just buy your RRSP and pay us the rest like a good little Canadian least we have to threaten you really is….so Canadian. Don’t buy into these things if you don’t want to, but do that because you have done the homework, not because CRA may not like it, of course they don’t like it, they don’t like us to have any of our money.

  140. Another note, just as it seems some here might have some relationship with a particular tax shelter so it also seems some work with/for the CRA.

  141. Canadian Capitalist

    @cxflyer: Let’s set aside the debate over whether folks who want to avoid donation schemes are scared of the CRA or not. Let’s look at it from a purely financial perspective.

    You make a $1,000 “donation” to a charity scheme and expect $1,500 back from the government.

    There are two possibilities:

    1. These donation schemes are deemed legit and you have a 50% profit to show for your troubles. Let’s be charitable and say the odds of this happening is 50%.

    2. CRA challenges the donation, denies it, you object, it ends in tax court and you lose. Assuming you didn’t have to pay any penalties or interest, you have lost your $1,000 “donation”.

    Your expected return from participating in a donation scheme is $1,500 * 0.5 – $1,000 * 0.5 = $1,000.

    The trouble is I don’t think the odds are anywhere close to 50-50. It’s more like a 10% chance of getting away with it or less. At those odds, your expected return is a loss of $750.

    That’s why I think these donation schemes make no sense whatsoever. I like to reduce my taxes as much as the next person and there are many legitimate avenues available that have much better odds of success.

  142. cxflyer: Are you calling me chicken? Who do you think I am? Marty McFly? Is that supposed to make me stand up to those Bullies at the CRA? I’m not 12. I make my decision based on facts, not emotion.

    The fact of the matter is that these people have NOT donated the money they claimed on their taxes. That’s why its being disallowed.

    I would like to point out one other small detail in the Banyan Tree article.
    Not only do these people have problems with the CRA, Robert Thiessen is calling in his loan. These people are getting screwed from both ends.

  143. Skeptical – In the 3 programs under discussion here for the last looooong time – NONE of them have money as the donation to charity in which they get a receipt, so that is NOT why they are being “disallowed” (by the CRA of course, & not by a court of law). You should know this. This is why the HEDAC charity is #2 in Canada – because the donations are of medicine & that is why they give 100% of the medicine away – because it’s NOT money, which can be spent or used in any way by a charity based in Canada, where there is no AIDS crisis.

    Canadian Capitalist – This is a forum for discussion. Quit trying to make it personal. You may as well call me a liar. I told you I am not a principle, nor an employee, nor an Agent for any of the aforementioned companies. I am friends with the companies, I promote the companies, & my friends & family participate in the programs. Don’t keep implying that I own one of the companies. By the same logic, ex-flyer has a good point – that you are working with the CRA. Get over it & don’t be a dork.

    Not one person has:

    1) Shown me that they know how these programs works (ie – no money donated & no inflated receipts for “cash”)
    2) Shown me any court precedent, policy, or provision in the ITAC that would serve to disallow the tax deduction entitled to the donor (Banyan Tree doesn’t count as it is completely different with the donation of cash & not one of the aforementioned companies that accept only goods, not money)

    Nobody has disproved that HEDAC charity, which was recognized by the CRA and Money Sense Magazine to be the 2nd best performing charity in Canada. (No, Canadian Capitalist, just because I say that, it does not mean that I work for the charity.)

    Guys, you’re not addressing the discussion accurately. People participate in these programs:

    1) Knowing that they will be challenged by the CRA
    2) Knowing that the companies make money from the goods they buy & donate

    Who are you to blame the companies for problems not yet proven to be problems in a court of law? Or do you think the CRA is the law? We don’t live in Nazi Germany anymore, guys. Why aren’t you directing your negative Nelly attitudes towards the CRA? They are the ones who “let these terrible programs continue”. They are the ones who refuse to give an advanced tax ruling on these structures. Ask yourself why? Really. Think about it. Why condemn companies that jump through all the appropriate CRA hoops & register for a tax shelter ID, & even ask the CRA to tell them first whether they think the program follows the law. The CRA has an agenda & this clearly proves it. It would be so easy for them to tell us whether a program “works” or not. Why don’t they do it? You know why – because all they need to do is say that one program works & they would lose too many tax dollars even if the law did allow it. The CRA has given these companies no choice & you know it. Now you blame the companies – shame on you. Call me wrong after 10 yrs when court decides that I’m wrong, but not until then. (No, Canadian Capitalist, just because I talked about Nazi Germany a few sentences back, it doesn’t mean I’m taking a political stance. Sheeh, what can a guy say here without you suggesting an ulterior motive?!)

    You are trying to “protect” people that know full well what they are getting involved with (or else they are not reading properly), who know that no court in the land has shown why they would fail, and who know the companies are getting paid. Get over it & come up with something relevant or even remotely intelligent that’s on topic.

    Please, somebody come back & tell us all again how “people are getting fake receipts for money that was never donated” or that “Money Sense & the CRA could still be wrong about a charity’s efficiency”. Funny thing is that you probably will…sigh…

    • Canadian Capitalist

      @Steve: If you are “friends” with these companies that is an affiliation. You are not here out of the goodness of your heart, you’re drumming up business for your “friends”. So, you are not exactly a neutral observer here and someone reading your comments should be aware of it. It’s nothing personal, strictly business.

      I suppose this thread is losing relevance. I’ve already pointed out why I would avoid these schemes. I have no idea how CRA will go after these arrangements, only that there is a significant risk that they will and participants face the risk of the donations being denied. That’s enough for me to stay away and I’ve pointed out that it should be enough for most tax payers as well. I have no interest in getting into a debate on whether CRA are like the gestapo. In a strict financial sense, the upside simply doesn’t justify the downsides. Your mileage may vary.

  144. Yeah, Yeah, big complicated scheme involving shell companies, shell charities, off-shore lending companies, etc, etc.

    Let me simplify it.

    First of all, I don’t care whether you want to call it cash, dollars, gift in kind, or drug credits. Its all the same thing. There all supposed have a cash value equal to what you claimed.

    You give X dollars.
    Smoke and mirrors to delay the CRA
    You get receipt for about 6X dollars
    You claim this value on your taxes for a refund.
    CRA automatically issues a refund for 2X dollars.

    Yay! You’ve doubled your money.

    CRA audits you.
    CRA disallows claim for 6X dollars, because you didn’t give 6X dollars.
    You pay back the 2X dollars, or you fight in court.

    PART3 – Hasn’t happened yet, but probably will.
    The promoter is charged with fraud as millions of $ of charity money vanished.
    The promoter has to come up with something to cover his butt.
    Promoter calls in his loans.

    So I encourage everyone to read the fine print on those loans. Keep you eyes open for a clause that says something about under performance of the investment. You may still be on the hook to cover the loan.
    Its been fun Steve, but I’m not making any money off this conversation so I’m probably going to let it die. If I really wanted t make some cash off this, I’d probably sign up to be an Ambassador. At the end of the day, the only guys that profit off this will be the promoters.

  145. Hahah Great emotion guys(girls) I actually agree. I would not “invest” in any of these as there is no question CRA will find fault..justifiably in the setup. They are at the end of the day a tax ponzi scheme. The real fault however lies in the CRA /Govnt not just shutting it down immediatly. Make the process of getting a TSIN harder. Pre approve the plan so these snake oil salesmen can’t grab the uninformed/greddys money.

  146. Aaaargh…

    No investment.
    No charity money disappearing, cuz there’s no money to disappear.

    Skepical, your comments have no logic. You’re just throwing things out there that have no relevance. Of course there SHOULD be a clause that states that you have to pay 100% of the loan back. That’s the point, my friend, there is a real debt that has to be paid back & these programs are not even tax shelters! They are deferral programs that in no way give you a ride for free. In these programs, everybody is told that they have to pay back their loans. That’s what makes these programs real & why the CRA has no leg to stand on. It’s the programs where you get something for nothing that raise eyebrows, not the ones that work like a credit card, where you buy something on credit & pay the debt back in full at a later date. This just shows yet again that you do NOT understand how these programs work (I thought you did) and yet you & CC are trying to tell people they don’t work based on facts you continue to show people that you get wrong.

    In ten years NO promotor has gotten “in trouble”. That should tell you something.

    HEDAC is the #2 performing charity in Canada as verified by the CRA and Money Sense. That should tell you something.

    The CRA cannot “shut down” these programs. That should tell you something.

    Real loans that have to get paid back. That should tell you something.

    I’ve given people law & facts that support my comments. You guys are giving fluff, inuendo, & speculation. You should do better or not comment at all. It’s misleading people.

    Canadian Capitalist – OF COURSE I’m taking a side here, that’s what this discussion is all about. If I didn’t take a side, there would be no discussion. You’re absolutely right – if I wasn’t a fan of these programs, I would not be writing this, but that doesn’t diminish the fact that I’m pointing out things that are accurate & irrefutable, so don’t try to cover up your inadequate comments by sloughing it off to me being one-sided.

    For sure these tax shelter programs are not for you guys, but you are simply not qualified to give other people “advice” on stuff you continue to show clearly that you do not know about.

    Guys, I’m sorry if you are feeling upset or frustrated by this thread, but I am too. I’d love to go for a coffee & show you how things work so you have a better understanding. I can guarantee that you will agree with me after we talk. Or at the very least, see why these programs are different, with no smoke & mirrors & how they follow the law. We may still agree to disagree on some other things.

    No, CC, I’m not suggesting we meet so I can secretly sell you one of the plans. I don’t even live in Canada. And I’m not suggesting a coffee because I’m a Tim Horton’s shareholder. No ulterior motive – I’m just really tired of having to correct you guys on what actually happens & it would be worth it to spend $5 on coffee & an hour of my time (excluding flight time to Canada) to straighten things out for you.

    Despite my sarcastic comments, I really do appreciate the friendly banter & I enjoy the challenging conversation. I’m sure you guys are all cool…


  147. I followed the COIP/MissionLife trail. I looked for the “charities” that actually pass out the drugs…nothing. One led to a loose association with a Kiwanis club in the east another to a church. Neither of whom have given any drugs to anybody. If the gvnt wanted to give me a 2 for one if I put money up to ship drugs to Africa they would do it simply not through third parties with complex schemes. In fact If I really wanted to give these drugs I could go and buy them overseas,cheap, and send them. It would buy MANY more pills per dollar, but I would only get a right off for the amount it cost me. I sat through the seminar, asked questions, many of which could not be answered like do you have a name and contact number for the person that is responsible for actually buying the drugs, and the name and number of the company that ships the drugs, and the name and number of the person that actually oversees the distribution. Funny, he didn’t seem to know that nor did he know how to get that info. Lest face it the Escort guy that changed his name and has been involved with COIP would not be allowed near a completely reputable organization. Maybe some drugs are getting to africa, good, but the paper trail to generate a leveraged position for tax purposes smells a bit. I don’t like CRA any better than anyone else but they can be a pain if you fall afoul. If this passes muster after CRA is done with it I’ll buy in because it is so good for Africa it will be operating for years to come, fulfilling Canadas aid commitments.

  148. Steve: I’ll say it again. I don’t care whether you want to call it cash, dollars, gift in kind, art, computer software, books, or drug credits. Its all the same thing. They are all supposed to have a cash value. Its supposed to be equal to what you claimed. Otherwise it’s fraud. Right?

    And thanks for straightening out that loan thing. I think that most of the people involved are under the impression that the loan somehow disappears. If you have
    to pay pack the loan, well, that makes its a complete waste of time. That means you’ve borrowed money to give it away to charity at some point in the future.

    That means your going to have to cough up the receipted value of 6X dollars.
    Who would actually sign up for this?
    That’s just stupid!

  149. Interesting points. From what I understand from speaking with friends and associates that have studied tax law, the courts tend to favour a plain meaning interpretation of the Income Tax Act. In other words, precedent cases reveal that unless the ITA explicitly states one cannot do “xyz”, then one can do it. This sheds light perhaps on why, although the original ITA was only ten pages long and and was a war tax levy on certain incomes (it was passed on September 20th 1917), it has now swelled to being a few thousand pages long, as people have legitimately participated in legal tax avoidance (also called tax minimization or aggressive tax planning) as it is their absolute right to do so.

    The CRA’s agenda, as cxflyer notes, is no less self-serving than taxpayers seeking to exercise their first right (See “Taxpayers Bill of Rights” on the CRA website), which states “You have the right to entitlements and to pay no more and no less than what is required by law”. I also know individuals that work as employees of CRA in the audit division, whose mandate is to collect ten times their annual salary as a quota or target. Those that succeed are promoted and/or entitled to bonuses (as would be expected for any employee thus incentivized to hit their target or otherwise do a good job).

    As Steve explained until he was almost blue in the face, each tax shelter structure one considers must be understood. It must also be weighed against specific anti-avoidance provisions in the ITA, and as well, against the general anti-avoidance rule (GAAR). A good due diligence measure may be, if you are a layperson and are genuinely considering participating in a particular tax shelter, to pay an impartial tax lawyer their hourly rate to assess and give their opinion on whether the structure is built to be in compliance with what is written in the ITA. If it is, you might consider participating.

    An important point no one has yet mentioned in this thread is the length of time it takes for a tax shelter (that has been reassessed by CRA, then objected to by the participant, then handed over to the tax lawyers), to move its way through tax court. This is assuming the tax shelter company one is dealing with has sufficient funds held in trust by a third party law firm to let the litigation and subsequent appeals run through the court system. The stats shared with me by lawyers who follow this process is that each tax shelter takes on average, between 7 and 12 years before a ruling or private settlement is reached. Here are more interesting stats:

    Statistics on Tax Litigation

    On November 22, 2009, at the Canadian Tax Foundation’s 2009 Annual Conference, Johanne D’Auray, Assistant Deputy Attorney General, Tax Law Services, Department of Justice, as part of the panel discussing current tax cases, presented some statistics.


    · Out of 16,000,000+ taxable returns filed by Canadian tax-filers in 2009:
    · Only 50,000 to 70,000 (out of millions of taxpayers) will object annually to the Appeals Branch.
    o 92% resolved administratively, (taxpayers have to or choose to settle for administrative settlements before accepting the expenses that come along with appealing to tax court)
    o 8% accept the cost and pursue an appeal to court

    · Of those who can afford to start the court process:
    o 1/3 cases are settled before court to the satisfaction of the parties
    o 1/3 withdraw and cannot or will not accept the expense etc..
    o 1/3 go to hearing and are able to bear the expense
    o In Tax Court, some win and some lose, but
    § in 2008-2009 161 were appealed to the Federal Court of Appeal

    · Of the remaining who can afford the appeals:
    o 15% of taxpayers beat the Crown (CRA) in lower courts
    o 28%* of taxpayers beat the Crown (CRA) if they can afford to cover the costs to appeal to the Supreme Court of Canada (*Note: 28% is based on all cases from 2003-Present)

    What is also interesting to note is that interest and/or penalties, to my knowledge, have not historically been applied as a punitive measure against taxpayers, once the ruling or settlement has happened, regardless of whether the taxpayer was legally required to pay back any or all of their refund. If anyone can cite a specific case of where this has happened, please share it.

    So, given the time frame of 7-12 years of having and making wise use of my tax refund ie. paying off my home mortgage years ahead of schedule, then re-routig the savings into prudent investments, or investing the refund in secure opportunities, or paying off high interest debt (and then axing the cards), even if the tax shelter is ruled against and 100% is due to be re-paid, I will be ahead after a 7 to 12 year period (assuming I am a good money manager and ensure the entire refund amount can be liquidated quickly should I need to pay an amount back). From where I sit, there is very little down side, and a lot of upside – the charity benefits, the taxpayer benefits, the tax shelter company benefits, and if the program ends up being ruled against as non-compliant, then the Ministry of Finance benefits from being paid back.

  150. Thank you Andro, from preventing me from banging my head against a brick wall out of futility…

    Skeptical – the donations are not supposed to have a cash value equal to what you claimed. You are supposed to claim your cost. There’s a big difference. Now, your cost can be what you pay now, or what you will pay if you use credit to buy it (ie – like a purchase of a good on a credit card that you donate). You then use the time value of $$ to take advantage of the immediate tax benefit NOW and pay the debt off later.

    Have a wonderful weekend folks!

  151. Steve: I think you are referring yo the Mission Life program when you say the loan has to be paid back.

    This is different from the COIP program where you prepaid the interest on a loan. That loan is ultimately paid back with replacement MUs. There was no clear explanation where those came from. I have to assume that they are from follow up customers. This would make it a Ponzi scheme as cxflyer suggested.

    The statement: donations are not supposed to have a cash value equal to what you claimed. You are supposed to claim your cost.

    A gift in kind is supposed to be given a fair market value. If you gifted a Rembrandt that you found at a garage sale, you can claim millions on your taxes. It would be accepted if it was worth millions, even if it didn’t cost you millions. When I gift my old van to the Diabetes society, they give me a receipt for the scrap value. They don’t give me a receipt for my original cost.

  152. Hi Skeptical,

    Yes, the Mission program is a bit different than the COIP program, you are correct, but my point is that there is a debt to be paid back, whether money or in pills that cost money.

    Actually, the Rembrandt example you gave is incorrect. If you found it at a garage sale & donated it WITHIN 3 YRS of acquisition, you can only claim the price you paid at the garage sale – The lesser of COST or FMV.

    FMV “otherwise determined” (eg by appraisers, etc.) is determined by FACT, while FMV 1st & foremost is determined by cost, which is LAW (way better than fact as it doesn’t vary from appraiser to appraiser, who use methodology that differs). The example of your old van works in reverse as it’s the “LESSER of the FMV or Cost and of course your Van depreciated over time, so you received the lesser of what you paid v.s. what it’s worth now.

    That’s a mistake that many people make, but if I bought the Mona Lisa today for $100 and donated it tomorrow, I could NOT claim the millions it’s “worth”, but rather only my cost.

    This makes sense, if you think about it, as “cost” is relative, while “value” is not. If people donated & got the “value” for their donation receipt, then people could be doing illegal tax-sheltering like crazy:

    Sony could donate laptops at their “value” ($2000) to receive 30% deductions ($600), while their “cost” to produce is only $400.

    You could go to a factory warehouse sale & clean them out of their “end of the season” inventory at 20 cents on the dollar & then turn around & donate them at the ir full $1 “value”, claim the receipt of 46.40% and more than double your money.

    Make sense?

  153. No Steve it doesn’t make sense.

    It doesn’t make sense because after giving me all these great examples, your going to say that this cost and value thing works everywhere except in the COIP program. In that example your going to tell me I can have a cost of $1400 and get a receipt valued at $6700.

    That part doesn’t make sense.

  154. Ummm…

    No, I didn’t say that. Cost IS $6700. The interest paid on the $6700 is $1400 and cannot even be deducted as it is NOT the cost of the item.

    Let’s tackle one thing at a time:

    We were discussing COST v.s. FMV “otherwise determined” (i.e. – determined by appraisers) and I was showing you where it’s the lesser of cost v.s. FMV. You suggested that you can buy something for a low price at a garage sale, donate it immediately, and claim a much higher value on the receipt used for tax deductions and I said that you cannot do that.

    You are now bringing up something different – purchases using credit, which is a completely different discussion. The interest paid on an item cannot be claimed or added to the price paid for the item.

    If you donated $6700 on your Visa card and paid interest only for the time being of $1400, you would not say that you only donated $1400. By the same tolken, if you purchased something on credit for $6700 and paid zero principle and $1400 in interest, you would not say that you only paid $1400 for the item.

    Big difference.


  155. “if you purchased something on credit for $6700 and paid zero principle and $1400 in interest, you would not say that you only paid $1400 for the item.”

    If I don’t have to pay the principle and my total out of pocket is $1400, then I would say I paid $1400 for the item.

  156. And what’s with that interest rate?
    $1400 to borrow $6700 for 2 months?
    Thats like 10% per month!
    Thats like 312% per year!

    Why don’t you use my bank?
    I’m getting 3.25% per YEAR.
    I could borrow $6700 for two months for less than $50.

  157. Correction on the above:
    It’s 212% per year!

  158. Skeptical. Please address the issue & we can move to topic 2 & 3 in sequence.

    You said you could claim “value” over “cost”. I corrected you. Now you are discussing what constitutes whether you have “paid” for something to validate cost. One thing at a time, please.

    Firstly, I think you have agreed with me that it is cost that matters, not FMV when purchasing & donating within 3 yrs. If I’ve got a “hell yeah” from you, then we can move onto topic #2: What constitutes a purchase & how much a person has paid (i.e. – cost) for the item.

    Yes, if a person never pays for their debt, of course it did not “cost” them anything. But, I think you are agreeing with me that IF they do end up paying for the item, then the interest would not count as part of the cost.

    Even in your example above, where the person does NOT pay for the item, you STILL cannot simply count the interest “cost”. Well, YOU said that you would say that you paid $1400 for the item, but there’s not a court in the world that would agree with you, so let’s stick to the law & not what you would consider as it really is the only thing that matters. The receipt would be $0 in your example as interest paid is the cost of BORROWING, not the cost of the item & therefore cannot be counted.

    Example: If you donated $1000 on your Visa, paid $100 in interest fees only & never paid off your Visa, your receipt should NOT be $100. It should be $0.

    Now, if I’ve got a “hell yeah” from you on that, we can move onto your latest topic of discussion (you are hopping around here like a flea on a hot griddle).

    Newest topic: A) Is the interest charged in that program excessive? B) The debt for the items bought does not get paid back

    Answers A) $1400 interest paid on a $6700 purchase for 2 months would be considered excessive according to The Canadian Criminal Code, Section 347, defines the crime of usury (called “criminal interest rate”) as follows:

    “Criminal rate means an effective annual rate of interest calculated in accordance with generally accepted actuarial practices and principles that exceeds 60 pr cent on the credit advanced under an agreement or arrangement.”

    But, (and this is a big J-Lo but), the $1400 you pay in interest is not for 2 months. It’s not even for 1 yr. IT’S FOR 3 YRS. It is simply paid up front and not monthly or yearly, thus tricking you into thinking it is only for 1 yr if you don’t bother to learn about the program. This is why it is dangerous for people like you to talk about things they don’t know about. You are misleading people.

    So, the actual amount of interest charged is $466.67/yr. divided by $6700 (using your example), which equals a very reasonable 6.9%.

    Answer B) Clients HAVE to pay back their debt for the $6700 worth of medicine! If you think they don’t, then once again, you don’t know the program. Please do not mislead people into thinking that A) the debt is for 2 months (I do not know where figured that out) and B) that the debt is forgiven.

    3 up to bats. 3 strikes.

    Please have somebody properly explain this program to you IN DETAIL before making any more comments here. It is very hard for me to educate you on the realities as they are somewhat complex and your constant mis-education on the matter is disruptive to evrybody’s thought flow. I’m sorry – I don’t mean to offend you, but we’re talking about things that simply are not as you think they are.

  159. After 61 days, donor refinances loan with secondary
    loan provider, PanAggregate Financial Corporation,
    (PFC) to lower interest rate to the minimum prescribed
    CRA interest rate and extend life of loan. PFC loan is
    only repayable in MUs

    So after 61 days, you no longer owe money, you owe medical units.

    Then soon after….
    PFC is paid back for initial loan with replacement MUs
    Amount owed to PFC after purchase of replacement MUs $0

    So a little after 61 days, the loan is cleared.
    Meaning you paid $1400 in interest to cover you for 61 days.

  160. “It is very hard for me to educate you on the realities as they are somewhat complex and your constant mis-education on the matter is disruptive to evrybody’s thought flow. I’m sorry – I don’t mean to offend you, but we’re talking about things that simply are not as you think they are.”

    As for misleading people: I think COIP is the one misleading people. Most of the people I’ve spoken to about this program are under the impression they will actually MAKE money off this program.

    As in:
    A) Put in $1544, get $3342 back, Net profit $1798

    Now your saying :
    B) Put in $1544, get $3342 back, repay loan @$6700. Net loss $4902

    So which one is it? At the end of the day is this a $1798 profit or a $4902 loss.

    Please don’t go off on a big tangent about how my brain is too small and how I don’t understand the intricacies of the program.

    Just cut to the chase:
    Do I have to pay the loan back?
    Do I make or lose money.
    Just pick A or B

  161. As to your statement that I don’t understand the $1400 is INTEREST.
    Haven’t you ever heard of total cost of ownership?

    What’s the difference to my wallet between:

    $19k for a car and $1k in admin fees
    $1k for the car and $19k in admin fees

    You can divy up and label each part any way you like.
    At the end of the day, its still $20k out of my wallet.

    What your calling “interest” isn’t really interest anyway.
    COIP’s expenses and Salaries must come out of that.
    The venues they present in don’t let them in for free.

  162. Skeptical

    Try borrowing & donating $1000 to a charity, pay $19 000 in interest on the loan and see if you can claim a $20000 receipt. WILL NOT HAPPEN & the law supports it. Your 2 examples are NOT the same.

    Sorry if my comments offended you. You are obviously a very smart guy. I will try to be more polite.

    A) You pay the loan back by borrowing with the 2nd company. The prepaid interest goes to that 2nd company, so only $78 of the interest (2 months worth) is kept by COIP. The interest rate is lower (min. govt prescribed rate), which means that it lasts longer.
    B) You never “make” money on a donation & the program is NOT sold that way. You MAY, however, do better in down the road if/when you buy pills. Nobody can comment on this until the purchase is made down the road. You may pay more for the pills (in which case, will you get an extra receipt? No.) You may pay less for the pills (in which case, will your receipt be reduced? No.).

    All money made by COIP & PFC combined is the $1400. After paying for Agents & the interest component on the pills, they are still left with a good amount of money.

    People are signing documents that clearly outline all of this & they acknowledge that they understand it. For Pete’s sake – they even tell people what to expect from the CRA BEFORE participating! Have you ever been to a corporate seminar?!

    Please read your information more carefully. You still are missing some key points!

  163. Skeptical:

    Your earlier comment: “What your calling “interest” isn’t really interest anyway. COIP’s expenses and Salaries must come out of that.
    The venues they present in don’t let them in for free.”

    Ummm…and I suppose you can’t say that the interest you pay to your bank is interest either because they use it to pay for their business operations?!

    It’s interest to YOU. To THEM it is revenue, which they can use for whatever they wish.

    I’m sorry, but I’ve never heard anything so foolish.

  164. I agree on the bank example and I’m glad that you finally understand what I’m getting at. I don’t care what you want to call my money after you’ve received it. If it comes out of my wallet I’m going to call that my cost. If you want to put some in the revenue bin and some in the interest bin, that’s fine. It makes no difference to my wallet.

    However, two posts and 10 paragraphs later and its still not really clear how much this program is going to cost me.

    The second loan is discussed, but you’ve avoided saying who pays it and what it’s paid with.

    So I ask again:

    $1798 up or $4902 down?

  165. Hi everyone, new to this whole thing, I have some questions that I don’t think were answered on this blog:

    1. Has anyone received an independant legal opinion on Mission Life or the tax shelter (defferal) program (or Fight Aids Save Taxes) (There seem to be alot of names involved). I would love to have a copy.

    I did ask the rep. we met with for a copy of their legal opinion and was told it was not public info. that if they released this to just anyone, CRA would be able to find a loop hole in the program and discredit it and then we would all possibly have negative tax consequences.

    2. The deal of the loan as I understand it, is you prepay 4 years of interest up front (I assume this is because when you receive the refund you will likely py off the loan and the finance company needs to make money (understandibly). After reading the financing agreement and all papers that come with it (I would be more than happy to email to someone that maybe able to understand it better than me) I see the loan is actually for a term of 8 years. So can I pay the loan off early and avoid paying any additional interest for the remainder of the loan period (of course I have already paid the 4 yrs prepaid). I was not able to find any info to this question in the financing agreement or maybe I just couldn’t find or understand it.

    3. So am I right to assume that you are not required to pay interest and penalties from the date of the donation tax year (the year you purchase and claim on tax return assuming they are the same tax year) up to the court decision if CRA is to win?

    4. Would CRA not then attach to your assets? Place a writ or caveat on your home? From my personal experience it has become clear that the banks will not lend money to repay CRA debt, so this in a concern of mine.

    I am being cautious but like anyone else I would like to have a better understanding before I get into something like this, risky yes but possibly worth the risk.

    5. What would be the actual cost of borrowing for the donation if you went over the entire 8 years of the loan. Say I paid $20,000 in taxes? Does the cost/benefit of borrowing for the donation still work out to my favour at least until and if the courts find for CRA.

    I also have a copy of the donation schedule that I can email to someone if this would help with the above. I just don’t get it.

    Thank you in advance to any of you that take the time to answer any or hopefully all of my questions as obviously I am clueless. Just trying t understand this.

    Is anyone willing to email and disclose if they are a tax professional or tax lawyer in Canada? I completely understand if you chose not to answer this and I respect your privacy.

    My email address if anyone would like to send me emails directly is: dianegp1-at-telus (dot) net

    Thanks again for reading my novel.

  166. I am not an accountant or a lawyer. I am not with the CRA or COIP. I’m just a guy that hates to see people taken advantage of. This thread is two years old and I jumped in late. The last couple posts from Steve seem to be indicating that the loan you get from COIP is real and it must be paid back in $.
    (Still waiting for him to confirm that!)

    If this is the case, then I can address #5.

    1) If you want to borrow money to give to a charity, then you don’t need COIP. Just pick your charity and write them a cheque. That will save you $1400 up front, and it will also save any legal hassle from the CRA. If you actually gave $6700 to charity, then you can claim it on your taxes. When CRA comes calling, send in the paperwork. End of story.

    2) If you borrowed the $6700 dollars from your bank, you would be entitled to the same refund as going through COIP: $3342 If you applied that to your loan, you would have $3358 remaining. Since your bank can probably offer a better interest rate than COIP. It would be cheaper to work through your bank. (3.25% vs 6.9%)

    You may chose to invest the refund instead of paying the loan back. However, you would have to invest $3342 wisely to turn it into $6700 in only a few years. Given today’s economic climate, this may be difficult. If you found an investment that could double your money in only 4 years, then I think it would make more sense to invest the entire $6700 (and anything else you an get your hands on!). You can always give something to charity when you cash out.

    SO… if the loan is real and has to be paid back with dollars…
    This COIP thing makes no sense at all.
    Your just paying $1400 for something you can do on your own.

  167. Thank you Skeptical, I appreciate your comments.

  168. Diane:
    I was going to let Steve respond before I posted again, but I just wanted to point out the following.

    Steve said in his last few posts that you have to pay the loan back. It is correct that you have to pay back the first loan. However, you do this by getting a second loan. So his statement is correct, but misleading.

    How the second loan gets payed off is unclear at this moment. If it gets payed off by earning enough interest to pay itself off, then you are left with your wallet being $1798 richer. Sounds good doesn’t it?

    The problem is that CRA doesn’t think you gave any money to charity. The $6700 never left your wallet. So you get to fight them in court over it.

    If your a millionaire with your own law firm like Brian Mulrooney, its probably worth fighting for a 50% judgment on $300k. If your Joe Average like me, its not worth going to court over a couple grand. Your lawyer will eat that up in a week.

    So there you have it:
    Option A: You have to pay the loan back:
    Your paying some $1400 to facilitate a donation to a charity.

    Option B: You don’t pay the loan back:
    You get to fight the CRA in court over your donation.

    I’m thinking its lose or lose.
    Especially when they won’t show the “secret” legal opinion.

  169. Thank you again Skeptical.

  170. Hi Skeptical,

    In answer to your question – It comes down to how much you can buy pills for to pay back your loan. If you can buy cheap, then $1798 up. If you buy middle, then maybe $1000 up. If you buy expensive, then $4902 down, but with the advantage of having the tax credit in your pocket for a few years.

    Now you’re finally seeing my point & I’m seeing yours – congrats on finally getting down this road! :)

    Not a very good “tax shelter” is it? But that’s what I’ve been telling people for eons here on this forum – it’s not one of those “slash & burn, get an inflated receipt & see you later” programs!

    By the time you pay back your debt, it’s after the 4 yr. statute bar period when the CRA can say anything about it anyway. Also, if you do better on the price of the pills, it’s NOT a capital gains issue as there is NO investment element (you couldn’t write off your interest, could you? Therefore no “investment” in the nature of trade).

    A very clever & compliant program. Not a tax shelter, but it HAS to register as one due to the CRA guidelines.

  171. Hi Diane & Skeptical,

    Sorry for the delayed response…

    Skeptical seems to be on the right track. Correction, though: The CRA neither expects or insists that any donation to charity has to be in cash. In fact, the #2 performing charity in Canada right now – HEDAC is #2 for receiving donations of GOODS rather than cash. You are absolutely, 100%, allowed to claim a deduction for your COST of the goods donated and this is fully supported by the Income Tax Act of Canada.

    The loan part is tricky, for sure. But loans can be paid back in money or in kind too. Not common, but not illegal (eg. -barter). If you don’t think it’s legal or taxable, etc. just ask your accountant what provisions are in place if you gave your drycleaner a haircut & he did your drycleaning as payment – both parties would have to record the COST of each “value received” and declare as income on their tax returns. So, perfectly legal & valid.

    Forget about all the interest, etc. It has no bearing on your receipt for the true COST of the gift and is money that you are “out”, the same as you would be out on the interest paid on your credit card if you bought a PRODUCT for $1000 with your Visa & donated it to charity. As the charity never receives the interest you pay to Visa, you can only claim the $1000 COST of the product.

    What it boils down to is whether you can buy less expensive medicine down the road to get your “debt instrument” (i.e. – coupon) back from the supplier of goods being donated & then you will be returning the EXACT thing that you borrowed, in this case to pay back your debt.

    The MLF & RLG programs work exactly the same & are a bit different than the COIP program, but the “finish” is identical. MLF & RLG are, in my opinion, even better than the COIP program, but are built on the same principles:

    – 100% philanthropy due to gifts in kind being donated instead of cash, which can be “misspent” by the charity
    – Zero fundraising fees charged to the charity
    – No getting receipts for stuff you don’t pay for (i.e. – not like those old Trust or Leveraged Cash donation programs, which are all but finished)
    – Finding clever, compliant, ways of settling your debt that may or may not work out for you down the road.

    Riskier, but rock solid legally as you simply can’t get “something for nothing” and if it is truly too good to be true, then perhaps it is.

    I can certainly put you in touch with many people working with either of those 2 programs to get you a proper understanding if you wish.

  172. PS – I’ve seen the legal opinion! I’m sure I can arrange for somebody to show this to you too. Remember, though, that a legal opinion means nothing with regards to CRA challenges & even though people insist on seeing it, it’s funny what happens once they do. They come up an emotional excuse why NOT to do it. Sadly, this is why these type of programs are NOT for most people as you have to think legally, not emotionally.

  173. Thanks Steve, it makes perfect sense. One other point I think it’s worthwhile to note is that the Mission Life and COIP programs (and I assume the RLG program, although I am not as familiar with this one) have used a portion of the money paid by donors to fund an arm’s length legal defence fund, held in trust by a third party tax law firm in Toronto. Well structured tax shelters will have several years worth of cash available to take the matter through tax court and 1 or 2 appeals – a process that usually takes several years. As well, only one test case goes through the court process – not all the donors. The one test case result will apply to all donors.

    This legal defence fund can only be used to protect the donors’ interests, as the CRA can and will audit ALL tax shelter programs, by way of a questionnaire mailed to each donor. Regardless of the responses, CRA will also ALWAYS take the opinion that (regardless of whether or not the tax shelter structure was built to be in compliance with the Income Tax Act) they are disallowing the refund, and that they want donors to pay back the entire amount with interest. This is called a Notice of Reassessment, and it typically comes in 1 to 2 year after the donor has received their refund. Of course CRA is going to audit and reassess all tax shelters – they are entitled to their opinion and they must make every attempt to fulfil their mandate to collect as many tax dollars as possible. They’d be stupid NOT to, as this intimidating process is their way of dissuading taxpayers from participating in tax shelters.

    However, this is the point when people panic, say they’ve ‘been scammed’ and write all kinds of warnings on internet threads like this one. Some donors then voluntarily pay back their refund, plus interest, and the CRA gets to boost its stats saying how many millions of tax shelter dollars they’ve disallowed, and how much interest they’ve collected from these ‘risky tax shelter schemes’.

    The sober, legal reality is that NO AMOUNT is due if a donor chooses to exercise their right to appeal ie. take the matter to court for a judge to decide on whether the tax shelter is compliant with the Income Tax Act. To do this, a donor must file a Notice of Objection within 90 days of receiving their Notice of Reassessment. The lawyers take it from there, and they get paid from the legal defence fund. In my earlier post, there are some encouraging stats, from the taxpayer/donors perspective, on rulings that have made their way through court. The outcome is pretty simple.

    Either the tax shelter is deemed by an impartial judge to be compliant or it isn’t. If it is, you’re helped a worthy cause, made great use of your money in paying down debt and participating to boosting the economy by investing in sound (preferably Canadian) opportunities and have expanded your wealth and sufficiency. If it is ruled on as NOT compliant, oh well, you’ve helped a worthy cause, had use of your money for several years (paid down debt, your home, whatever, invested in sound opportunities) and pay the refund back as per the judges ruling. One should still have expanded their wealth and sufficiency if they have been prudent with their refund money and not blown it on a trip to Mexico. I am not aware of situations where interest or penalties were ever mandated by a judge once a tax shelter has moved through the appeals process, regardless of the ruling. Again, if anyone can cite a specific example, please share it.

  174. Canadian Capitalist

    @Andro: My understanding is that anytime you have to pay back taxes, you have interest and penalties assessed as well. Otherwise, tax payers will conveniently make mistakes on the return if the only consequence is making good on the mistake. Others can weigh in but I believe that’s how it works and would be very surprised if it is otherwise.

  175. Canadian Capitalist

    @Steve: So, let me get this straight.

    I buy $6,700 worth of drugs from a private company.

    I’m advanced a loan to buy $6,700 worth of drugs from a private company. I pre-pay $1,400 in interest on the loan.

    A few months down the road, the loan is transferred to another company and a few years later you pay back the original loan with medicines.

    It is your *opinion* that this is all legitimate. To me, it sounds like an elaborate shell game and taxpayers participating in it are taking a huge risk.

  176. We’ve been told by Steve that this scheme MIGHT not work and that maybe we should avoid it.

    We’ve been told by the CRA that it WILL not work and we should definitely avoid it.

    I’m going to listen to both of them.

  177. This whole argument is completely pointless. Bernie Madoffs ponzie scheme relied on people wanting to get something for nothing. This is a tax ponzie scheme. Does anyone really think they can get something for basically nothing? You can argue the legalities all you want but in the end it will collapse and those Madoffs on the sideline taking the “investor” money. They will be long gone. If it sounds too good to be true…it probably is.

  178. cxflyer: Yep, it is kind of pointless.
    This is what, version 16? of a buy in low, donate high tax shelter?
    This one will collapse just like the other ones.

    People will still line up to put money into version 17.
    They never learn.

  179. I’ve been going through the threads on
    All I can say is: Wow! Lots of people getting screwed.
    I think I’ll have to change my name to Cynical!

    So much to read through! Not sure I’ll have time to come back.
    Its been fun folks! Thanks for putting up with me!

  180. Seek and yee shall find…

    It seems the COIP program has had a few small problems with the CRA….

  181. post 186 from Cynical…the link to “thestar”, that is almost the exact information that i received from CRA for my 2007 COIP donation, that the donation was disallowed.

  182. Canadian Capitalist

    @Cynical: All I can say is “wow”. So much for Steve’s sky-high praise of COIP:

    “highest performing charities in Canada”

    “100% of the donation goes to actual charitable works”

    “100% of them go to dying people in Africa #1) because the charities have forensic audits…” blah, blah, blah

    Here’s what CRA says about COIP:

    “the CRA has not been provided with sufficient evidence to substantiate that the promoter purchased the pharmaceutical units, that the charity ever received the pharmaceutical units or that the pharmaceutical units even exist”.

    @Skeptical: It’s breathtaking to surf through those Canadian Business Forum threads. It is incredible that these donation schemes continue to flourish despite the long list of people who have been burnt by these programs.

    CRA’s position on what constitutes a gift is devastantingly simple. If a gift doesn’t make you poorer than before you made it, it’s not a gift! All I can say is, use your common sense folks. If you effectively spend $1,400 and receive a net benefit of $1,700, it is not a gift. It’s as simple as that.

  183. Thanks for chipping in AnotherCOIPer. Up until this point I had no confirmation that the COIP Program had been disallowed. Funny that Steve never really brought it up. He’s known about it for over a year.

    I suggest that everyone read over the Banyan Tree threads on COIP may follow their lead.

    1) Sorry, the pills cost more money than we thought they would.
    Send more money….

    2) The defense fund has run out.
    Send more money….

    This looks like it could be COIP’s last big year.
    Next year … Mission Life!

  184. @ Andro – perfect understanding. 10/10. If you were selling tax shelters, I would buy from you as you know your stuff. We need more people like you on this forum as these guys keep forgetting what I’m telling them & haven’t bothered to understand these programs. I’ve got one guy here who thinks it’s a Trust structure like CHT & another guy who thinks that the program is “bad” because the CRA has decided they don’t like it! Haven’t I been explaining from the beginning that the CRA’s opinion means nothing until a court decides who’s right & who’s wrong? Are you the only person who’s been reading? Sigh…here we go again…


    @ Canadian Capitalist – There have been many cases where the CRA is NOT awarded penalties & interest due to many reasons. There are also many cases where the CRA makes a deal. Keep in mind that the CRA CANNOT afford to lose in court as this would mean that 34 million people in Canada could participate in the shelter & save taxes. Better to threaten & make deals to ensure people never do it again than to risk being obliviated by a loss in court – even if it is a 1% chance of loss! is an example of how the CRA was not awarded interest.

    @ Skeptical – No, I never said that the program “might not work”. It works according to the law. It’s to what degree you may come out ahead financially that I was tempering. You can’t get something for nothing, remember?

    @ Skeptical – No, CHT is nothing like COIP. CHT gave you FREE stuff from a Trust that you donated to charity & got a receipt for. Inflated receipts v.s. what you paid (which was $0).
    Sorry – 0/10

    @ Cynical – Having “problems” with the CRA is something that COIP tells it’s participants before participating. That link was simply the expected CRA proposal for reassessment that they say 100% of participants in 100% of tax shelters will go through. Yet they keep on letting companies promote. Doesn’t that tell you something? It’s not what the CRA thinks people – they have an agenda: TO COLLECT TAXES. Let’s see what the law says as it’s the only thing that matters. Gotta get with the program here, my friend – 5/10

    @ Exflyer – Correct that you can’t get something for nothing. But that is why these new programs are good, because you don’t get something for nothing. Thank you for your support on this. If you are surprised by what I’m saying than take another look. Skeptical just saw the light & you just may too.
    See the above comments re: NOT getting something for nothing – 7/10

    @ Canadian Capitalist – Ummm, yes I’ve said from the beginning that all tax shelters will be challenged by the CRA. The disallowment is expected & I’ve been telling you that for ages. Just read the earlier threads & you’ll see proof of that. The CRA’s position things is meaningless once a Notice of Objection has been filed. Only a court decision is what matters!

    @ Canadian Capitalist – By your own flawled logic – whatever the CRA says must be right, eh? They never make mistakes, I guess, huh? Riiiiiight…..
    Lives in lala land: 0/10

    @ Canadian Capitalist – Please read the posts before responding to them. I never said that COIP was one of the highest performing charities in Canada. COIP is not even a charity!
    Not reading: 0/10

    The CRA has conducted a forensic audit, which passed 100% and I’ve got a copy of the paperwork to prove it. If anybody would like to see it, please let me know & I will e-mail it to you!

    Proof of this is that if the pills didn’t exist, there would be no legal challenge. Besides, haven’t you seen the video from the accounting firm that went down to Africa with the charity (not COIP) and videotaped the actual clinic with boxes & boxes of medicine with COIP on it to hundreds of people lined up? I guess that whole thing was staged, eh CC? Again – if you would like a copy of this, please let me know.

    Guys – come on. That stuff is easy. That’s not what the CRA is having issues with. These companies have build a better mousetrap & the CRA is trying whatever they can to deter. It will all come out in court – again – the only thing that matters.

    Do you honestly think the CRA has YOUR best interests at heart?

    @ Canadian Capitalist – Your oversimplification of what you think defines a gift is simply wrong. I do not even think that the discussion of “impoverishment” is at all relevant, or in question, and I think that most people (even professionals) misconstrue the legal importance of the concept, as it is not actually a tax law concept. It derives from the civil law as the counterpoising side to the doctrine of unjust enrichment.
    Laking on the legals: 3/10

    @ Cynical – Please get up to speed. I’ve been saying for a looooong time that all programs will be challenged by the CRA. I have been guaranteeing people this would happen on this forum for months. COIP people tell donors that before they even sign up! Don’t you get it? That’s not the topic of discussion.

    The COIP program has not been offered since Jan, 2009. It’s only RLG & Mission Life being offered in this “type” of a tax shelter program.
    Poor homework done here: 1/10

    Ding! Round 645…

  185. @ Canadian Capitalist: I mentioned HEDAC as the #2 performing charity in Canada as evidenced by the CRA & Money Sense Magazine & even gave you the link. How could you say that I said “COIP was a good charity”?! The charity working with COIP was the Orion Foundation who gave it to Direct Relief for 3 yrs. If the pills “never existed”, then the charity would be shut down & I think that Direct Relief would have figured it out within 3 yrs, right? Orion is not shut down & Direct Relief (’t have the wool pulled over ther eyes. That should tell you something. Don’t believe the hype!

    For those of you who would like to see a thank you letter from Direct Relief (one of the top charities in the US) for all the pills they received, that the CRA says doesn’t exist, then please let me know! Maybe if I show that to you, I will do the impossible & show you that the CRA sometimes doesn’t play by the rules. Sorry to burst your bubble.

    I’m sure that AID for AIDS would work with a charity that is not delivering medicine to Africa: They just partnered with HEDAC. Guess what? Mark my words, guys, when it’s time, the CRA will say that the medicine going to HEDAC

  186. I’m pretty sure that Robert Thiessen had lots of paperwork and glossy photo’s to show people that started asking questions. The longer you can maintain an air of confidence in the program the more people will buy in.

    Every other version of these programs has turned out to be a con an your
    progressing along the same path.

    Phase 1 of the business plan: Sell tax receipts. (Call it “Interest”)
    Phase 2: Ask them for more money for the legal defense.
    Phase 3: Ask them to pay back the loans.

    An interesting point on the loans. The loans are held in Medical Units and not cash. What will be the value of an MU in 7 years? If the loans are brought back into Canada, it could be a lot. The value of an MU has been going up in Canada. These people are financially liable for a loan who’s value is yet to be determined.

  187. Shy Kurtz, identified in the Aids For Aids photos as being from HEDAC. He is a principal on the Mission Life team. So the promoter also runs the charity. Note that Money Sense is also listed as being part of the team.

    As to the agreement…

    Your on vacation in the Dominican Republic.
    Call up Aid for Aids
    Sign “a letter of intent”
    Pose for some picture
    Write off the whole trip as a business expense.

    Takes what? an afternoon? Did they buy ya dinner too?

  188. This Shy Kurtz?

    Crikee! Are you sure this isn’t coach from Survivor?

    I could barely contain my laughter when I read this bio.

  189. “@ Cynical – Please get up to speed. I’ve been saying for a looooong time that all programs WILL BE challenged by the CRA. I have been guaranteeing people this WOULD HAPPEN on this forum for months. COIP people tell donors that before they even sign up! Don’t you get it? That’s not the topic of discussion.”

    See now you completely missed my point.
    WILL BE and WOULD HAPPEN is completely different from HAS BEEN and HAS HAPPENED.

    You’ve been misleading people about the current status of the COIP tax claims.
    Its not:
    “going to be reassessed”

    Its no longer a question of IF you go to court, its WHEN.
    You haven’t given these people any tax break,
    You’ve GUARANTEED them an expensive court battle.


    And why is the COIP program no longer offered? You keep saying its all legal, no problems with the CRA, everythings great. In fact in Post 138 you said:

    “COIP, RLG, & Mission Life are all still around & are not disappearing. ”

    Now your saying it disappeared a year ago?
    Some problems your not at liberty to discuss?

    “@ Skeptical – No, CHT is nothing like COIP. CHT gave you FREE stuff from a Trust that you donated to charity & got a receipt for. Inflated receipts v.s. what you paid (which was $0).”

    No, I said COIP is like CHT and it is:
    1) You pay interest or fees, or into an investment and receive a tax receipt worth way more than you put in.
    2) Aids drugs are supposedly bought on your behalf and distributed in some foreign country. The purchase and distribution of all the property takes place on foreign soil.
    3) The loan/trust property is held in a private company in a foreign country.

    Sure they called it a “Trust” instead of a “loan” but its pretty much the same game now isn’t it? Please feel free to go on and on about how the terminology makes such a huge difference and that the COIP program is COMPLETELY different because we had different forms for people to fill out.

    @Steve “No, I never said that the program “might not work”.

    I’ll give you that one. You never specifally said “the program might not work”
    However, you did say:

    POST 128: “I wish you the best in your financial/tax lives and I beg you to NOT participate in any government registered tax shelters EVER. You will be
    doing yourself a favour.”

    POST 140: THEN, if you don’t pay (assuming you don’t take a deal from the CRA before hand and actually lose in court after 1 or 2 appeals) you can get in trouble.

    POST 176: “Not a very good “tax shelter” is it?”

    I took all that and paraphrased it as “might not work.”


  190. If anyone is interested:

    They were taking in COIP donations and disbursing them to Orion.
    I can see how you could get pretty big doing stuff like this.
    You could be a million $ charity with close to 100% disbursement!

  191. Canadian Capitalist

    @Steve: I understand COIP is not a charity but a tax shelter just fine. I’m simply pointing out your sky-high praise of the charities and CRA’s position that there is no sufficient evidence that the pharmaceuticals even exist. Sure, CRA might make mistakes but there are far more believable than folks on this board claiming to be privy to forensic audits.

    I couldn’t care less what your opinions on this subject are. It’s clear which side your bread is buttered. What I’m hoping is that others who may be considering participation in these tax shelters have a clear idea what they are getting into. Sure, it will feel great to stiff the Government but rest assured that the feeling will pass. When it’s all said and done, you might come to rue the day you heard about these shelters.

  192. Canadian Capitalist

    For those who are interested, check out what the worst-case scenario could be according to this website:

    To add insult to injury, participants in past shelters are being sold warranties to “protect the refund”!

  193. The Mission Life Loan Agreement is on line:

    It doesn’t really matter is Steve shows you the secret legal opinion:

    Your Acknowledgement of Risk:

    3) If the promoter has received tax or legal opinions from its own legal counsel,
    I understand that that these counsel do not act for me, and that I cannot rely
    on their opinions or on the promoter in deciding whether to participate in
    the MLF Program and whether it is suitable for me.

  194. The Newsletter contains a list of charities that had their charitable registration
    revoked in 2009 due to tax-shelter related non-compliance.

  195. Steve has some strong points.
    Cynical–look at the list. COIP is not mentioned. They must be doing something right???

  196. So I’m looking through the fight aids save taxes presentation:

    I’m looking at the photo of the Logipharm plant and I’m starting to get impressed with their nice clean, organized facility when…

    Hey! That’s not a drug manufacturing plant! That’s an SMT electronics plant.
    I see solder paste screening machines, pick and place machines and IR reflow ovens.

  197. @Anna: Cynical–look at the list. COIP is not mentioned. They must be doing something right???

    You mean my list on You are correct. COIP is not listed. They are not a charity. However, their involvement in Healing and Assistance Not Dependence Canada is what lead to that revocation.

    See post 196

    COIP is getting charities shut down.
    They must be doing something wrong???

    • Canadian Capitalist

      @Anna: COIP is not a charity but a tax shelter. Charities that COIP works with have a habit of getting into trouble with the CRA. Apparently, the All Saints Greek Orthodox Church referred to in the CRA document is in trouble as well.

      @Cynical: That’s so funny that the picture in the FAST presentation is from an electronics plant. I’ll bet that Steve has possession of a super secret forensic audit of the presentation somewhere.

  198. If the charities have undergone a “forensic” audit and passed, they should receive a letter of compliance from the CRA.

  199. I verified with my documents and the years I donated to COIP, none of the charities are listed on the not the CRA site.

    The CRA must also be responsible. Before I donated I called them and they told me that COIP was the strongest program. He could not say anything negative.
    If i called them to verify, why is it wrong now?.

  200. 1) From Post 23……

    Anna // Dec 27, 2008 at 10:39 am

    I agree. I tried to get as much info as possible and every time I call the CRA they never have a straight answer for me other then “do not get involved”. That is unacceptable answer. I will donate this year and hope for the best.
    I truly can not find anything wrong with this program.

    Thanks Steve, greatly appreciate it.

    2) The CRA’s official position on Tax Shelters since 2006:

    I find it really hard to believe that you could get anyone at the CRA to comment on anything due to privacy laws. All they can do is confirm the Tax Shelter #.

  201. YES. they always confirmed the tax Shelter number and they always told me that it is a risk BUT they also confirmed that they was no warning against the Tax shelter numbers i provided.
    If it was so illegal..why doesn’t the CRA shut it down!! That must tell you something.
    Up to date, no program had to reimburse 100% of their donation. People give in because they are scared.
    Only time will tell…

  202. Anna:
    1) The CRA cannot comment positively, or negatively on an organization until they have won (or lost) in court. They could be sued if they were revealing information. Refusal to provide information should not be interpreted as approval.

    2) What COIP/Mission Life is doing is LEGAL! They are talking you into giving money to a charity and delivering a receipt to you.
    What your doing is LEGAL. You are claiming a deduction on your income tax that may, or may not, be accepted.
    Its only ILLEGAL if you lose in court and you still refuse to pay.

    So when you ask Steve: “Is this gonna work?”
    and he answers “It’s all LEGAL!”
    Your interpreting that as – Its gonna work! I’m gonna make some money!
    He didn’t really say that now did he? LEGAL != WILL BE ACCEPTED.

    3)These cases take years to settle. These programs depend on that. You buy in the 1st year. Seems to be working. Double it every year after that…. Get your friends into it, then …. collapse.

    4)These programs are money losers even if you have to reimburse only 50%.

  203. Whoa!

    I can’t leave you guys alone for a minute, can I…

    Cynical – The CRA warns against 3 types of structures (note, I said “warns”, not “says is illegal”):

    1) Leveraged Cash programs
    2) Trust structures
    3) Buy Low/Sell high programs

    COIP, RLG, & Mission Life are none of these.

    “Sure they called it a “Trust” instead of a “loan” but its pretty much the same game now isn’t it?

    Your statement above is laughable. Have you ever set up a scholarship TRUST fund for your child? Have you ever set up a family TRUST? Replace the word “trust” for the word “loan” and see how similar they are.

    Ask your bank if you can replace all your loans with trusts, then and see if they think it’s the same thing. Sorry 1/10 on your logic for this one, my friend.

    @ Canadian Capitalist: I respect what you are trying to convey, but the medicine exists. Direct Relief has said they received it. The CRA has accepted the forensic audits that COIP supplied. Why wouldn’t the medicine exist? That’s the easy part. The program works & all the companies make LOTS of money WITH the medicine existing! Why would they risk something obvious like that. That’s the thing that gets programs shut down for fraud. NONE of these programs has been shut down. Think about it.

    @ Cynical: If COIP was getting charities “shut down”, then the Greek Orthodox Church would be shut down & the Orion Foundation would be shut down. They aren’t. If you would like to see my “super secret forensic audit”, please give me your e-mail address & I will send it to you. But please come back on the post & let people know you have seen it & that you recant your accusation, okay? I hope you can walk the walk as much as you can talk the talk and I promise not to say “I told you so”. Let’s do what’s right here, okay?

    @ Cynical: Do you ever think about what you say before you say it? If COIP tells people that their program will be reassessed before participating and people still buy because the reassessment does not determine whether your tax deductions are valid (only a court can do that after a Notice of Objection is filed) then why, when the reassessment does come out would that cause any change in the thinking? Emotionally, however, new people buying would rather be participating in programs that have not YET been reassessed, so they would look elsewhere if there are similar GOOD programs available. COIP couldn’t compete once they were reassessed, but the CRA did not stop them from marketing (they can’t) and people could continue to buy if they chose to.

    Fact – COIP stopped marketing in early 2009, so I’m not sure what you’re barking about. 1/10 on your research & illogical thinking.

    @ Anna – Good for you! It’s hard to come onto a forum like this where people promote fluff & don’t stick to the law. You are sticking to the law & proving people wrong here. We all know that the CRA doesn’t warn against any of the 3 structures we’ve been talking about, yet they say they will reassess all tax shelters. Donors will then file a Notice of Objection, which removes the CRA’s opinion on the tax shelter from doing any harm. A court will now decide what happens & the CRA will start to make deals with the donors because they can’t afford to lose in court. All these new programs tell people exactly what will happen before they participate & the people on this forum are complaining that the tax shelter companies are the bad guys! Unbelieveable…

    @ Cynical – Just when I thought you were absolutely bonkers, you surprised me. What you said in your last comment is 99% correct. Thank you for allowing me to hold out hope for you!

    Here’s where you’re wrong. Not 1 program since Klotz & Nash has lost in court and the CRA settles many cases out of court. If you get a deal @ 50% of your money, you WIN. You’re forgetting about the earnings potential of that $$ over the course of many, many yrs. Rule of 72 pal, @ 7% interest, your money doubles every 10 yrs. If you go the distance, however, and these newer programs win in court, then you keep everything. The best lawyers in the country can’t find problems with these programs, so you think the people on this forum & the CRA can find issues? Come on.

    Guys – You know what would make everything much simpler? If the CRA simply told everybody whether they felt these programs follow the law or not. They have an opportunity to do this right now. They issue Tax Shelter ID #’s and then refuse to tell the promotors whether they feel the program works. Do you know why they don’t do this? Because they are afraid of the 1 program in 10 that might actually work! Think about it. If ANYBODY can answer this question for me, then please tell me. This is my whole beef about this forum – you are placing the blame on the companies that are doing what they feel works & are selling to donors that feel these programs work. The promotors get legal opinions from law firms saying they work, so why won’t the CRA take a stance BEFORE participating to save everybody all the trouble?! Think about it.

  204. Just re-read my e-mail. I’m fending off so much BS from so many people, I mentioned the forensic audit offer to Cynical, when I meant to offer it to Canadian Capitalist.

  205. Canadian Capitalist

    @Steve: I have nothing to recant (my email is cc at BTW).

    You say CRA has “accepted the forensic audits that COIP supplied”.

    Really? Here’s what CRA says in its notice of reassessment to the taxpayer.

    “the CRA has not been provided with sufficient evidence to substantiate that the promoter purchased the pharmaceutical units, that the charity ever received the pharmaceutical units or that the pharmaceutical units even exist”

    Doesn’t sound like acceptance to me. Feel free to ask CRA to recant.

  206. I am fully capable of calculating this using compound interest. Since we don’t know those values, lets keep it simple and do the analysis as though the entire transaction takes only one day:

    We will start at noon and end 7 years later at 7 p.m.

    12:00 noon to 12: 15 (3 months)
    The donor gives $1400 to COIP, gets a receipt for $6700 and gets a refund for $3342.

    Donor: $1798
    COIP: $1400
    CRA: -$3342

    2:00 P.M
    CRA phones and says forget it, you fight for a year and on 50% of the $3342 you received. You pay them back $1671.

    Donor: $127
    COIP: $1400
    CRA: -$1671

    7:00 P.M.
    COIP Phones and wants to close out the second loan. You owe them $6700 worth of pills. The pills can be bought at a better price than $6700, but nobody said they would be free. Lets say COIP lets you off easy and only asks for 20% of the Canadian FMV.

    Donor: $-1213
    COIP: $2740
    CRA: -$1671

    Are you starting to see who’s winning this game?

  207. Steve: I’m not trading my email address with anyone on this forum. These programs are worth millions and we naysayers are a thorn in your side.

    I have searched the CRA website and there is no such thing as a “Forensic” audit. Just a plain old audit. If Orion has passed one, then they should have a letter of compliance. If COIP or Mission Life had that, don’t you think they would post it on their website? Wouldn’t that end this discussion? Wouldn’t that be a great marketing tool? While Steve offers bravado about “Forensic” audits, I hunt down documents that show the true relationship.

    Wake up folks. After Steve and friends have split up your $1400, there’s nothing left! There are no loans. There are no pills. There is no charity work being done. Just Steve trying to line his pockets with your money and leave you fighting with the CRA.

  208. @ Cynical – You continue to show the world that you still don’t know how these programs work. I cannot keep wasting my time with you if you don’t listen. When I move to Canada, remind me to show you how everything works. Let’s see if I can clarify:

    COIP: Buy $6700 worth of medicine & Pre pay 3 yrs interest (X%/yr) totalling $1400. Debt can be paid by paying $6700 in cash or $6700 worth of pills with proof of purchase.

    Pills are donated to a charity. Law says that you cannot claim the $1400 in interest paid to a company for the pills purchased, but only for the purchase price of the pills. The law says you can buy now &
    pay later up to 10 yrs and if a min. Amount of interest is paid.
    Check & check. You receive a receipt for $6700, which is the price you paid for the pills, despite the fact that you haven’t paid off the debt yet (credit card donation example).

    You receive a tax credit of approx. $3100 (46.4%) (I’m working without a calculator right now). You’re up (in cash only, not on paper – just like a credit card donation or if you bought something on credit & will pay it off later)

    You settle your debt with COIP early (61 days later) before the pre paid interest runs out by buying MORE pills from a different company, PFC, on credit again & transfer the balance of PPI from COIP to them.

    The new debt to PFC is paid back in pills only in 3 yrs time, leaving extra prepaid interest left over due to a lower interest rate charged.

    Donors expect to be able to buy pills at a much lower price on the world market using the leftover pre paid interest. If the don’t think they can, then they don’t participate.

    IF donor can buy cheap pills with THEIR own left over pre paid interest, then the only other money at stake is their standard tax credit of $3100 – the $1400 PPI = $1600 net cash flow positive position.

    If CRA challenges the $6700 receipt and makes a deal with the taxpayer for 10 cents, 20 cents, 30 cents on the dollar or if the program wins in court and the donor has used the $$ wisely or if the donor blows the money & the program wins in court (it should, based on law), then the donor comes out way ahead. if the donor uses it to pay off 18% Visa bill debt, they win EVEN I’d they lose in court. Anything else & the donor loses. If you think the program works differently, you’re wrong. If you plan to do something differently & ignore the known risks – don’t participate.

    Cynical, I participate in these programs – I’m a customer! If I know this ahead of time, then who are you to complain for me? I know the risks & I am prepared to take them.

    I put my money where my mouth is too as my wife & family all participate. Who are you to tell us what you THINK we’re missing?! Get over yourself.

    It’s obvious that:

    A) You know nothing about how these programs work
    B) You are telling people on this forum that I work for COIP to try & stir up problems for me

    Proof of the fact that you have no interest in reading or learning is obvious. I mentioned in my last post that my intention to get the forensic documents via e-mail was for Canadian Capitalist, not you, yet you still rambled on.

    In one breath you say how these programs are a tax sham & the next breath you prove with your own words that they are legit from a tax standpoint, but that the math doesn’t work. Which one is it?

    @ Canadian Capitalist – I’ll e-mail you those audits (done at the CRA’s request, by an auditor of their choice) shortly.

  209. Steve,
    I am interested in seeing the audits. Can you please email me.

  210. ANNA—-great to see you still plugging away with COIP. enjoy your tax credits and also give MISSION LIFE FINANCIAL a turn down the road. they are both the safest tax shelter out there. the cra i feel will not go to court because the cannot afford to loose. THE LAW MUST PREVAIL AND THE GOVERNMENT MAKES THE LAW NOT THE CRA.

    THANKS ALL: enjoying all the comments.

  211. 1) If Orion has passed an audit, then they should have a letter of compliance from the CRA. Show us the audit.

    2) If the second loan is paid out by supposedly buying pills with the left over interest, then we are back to square one. The donor never really gave any money to charity. Its just paper shuffling to sell tax receipts.

  212. Steve: When I move to Canada, remind me to show you how everything works.
    Steve: Cynical, I participate in these programs – I’m a customer!

    Do I need to point out the obvious inconsistency with these statements?

    Steve: You are telling people on this forum that I work for COIP to try & stir up problems for me.

    Uhmm.. you’ve already admitted that you are connected with COIP. How else would you have access to confidential tax audit information about canadian charities when you don’t even live in this country?

    Steve: @Cynical – I cannot keep wasting my time with you if you don’t listen.
    O.K…. So why do you keep coming back? Do you think you are the world’s greatest salesman and you are going win me over? Let me make it clear: We will NEVER sit down and discuss this over coffee. I am NOT a potential
    customer. STOP wasting your time with me.

    The only reason that anyone would buy into this is emotion. That emotion is GREED.

  213. Steve: Just re-read my e-mail. I’m fending off so much BS from so many people.

    Why would so many people be sending you emails about this? I thought you were just another anonymous donor? I had no idea that anyone was even following our little debate!

    Anna: When an audit is performed, the CRA will issue a letter stating the results.
    That’s what you want from Steve.

    Here is an explanation of the audit process:

  214. Steve,
    I bet you go real quite in a year or two. You know after CCRA asks for its money back. You have to be involved in selling this thing as you certainly “waste” a lot of your time trying to convice everyone of its legitimacy.

  215. Canadian Capitalist

    @Brian: Yes, CRA does not make the law but it’s interpretation is quite different about these tax shelter schemes:

    1) CRA disputes that the donations qualify as a gift because (a) it doesn’t believe participants held legal title to the pharmaceutical units (b) the transfer of property was not voluntary (c) material benefits were derived from the transactions.

    2) CRA disputes the FMV of the pharmaceutical units and says the values are “inflated”.

    It looks like the battle is headed for the courts but I want to address claims that CRA will settle for 10, 20 or 30 cents on the dollar. Here’s what the guys who are selling “warranties” against an adverse tax decision for those who participated in past shelters are saying:

    “The last three cases that went to court, which dealt with Tax Donation Deals, the tax payer lost all of them. The Fair Market Value was reduced to the tax payers purchase price. As well, interest was added to the amount owing, but not penalties. ”

    Doesn’t sound like the CRA settled for pennies on the dollar to me.

  216. @ Cynical

    Sigh…Cynical, you’re not reading AGAIN. You just said that “…the donor never gave any money to charity…” I’ve been telling you that in these programs you DO NOT GIVE MONEY to charity, you give goods for the large donation. Can’t you absorb this? No money. Zip, nada, nothing. No cash donations to charity – goods. Are you even reading this forum?

    A charity proves it’s good standing by keeping it’s charitable status each year. The Orion Foundation is a charity in good standing with the CRA currently & always. There is your proof. If you don’t think that charities can lose their status, then think again – the proof is all around you. Just read the CRA bulletins on their web site.

    Cynical – We’re discussing programs that have been around for 4 years. I don’t live in Canada presently, but I lived there a short time ago. Ever hear of airplane travel? That does not change the fact that my wife, family & friends have all participated in thes programs & currently do now. I’m a participant & you are trying to tell me that I’m being “tricked”? I know the deal & I don’t need you to save me. Quit trying to give me advice, okay? I do not respect your acumen when it comes to tax law, so you can stop trying to convert me.

    I have never been trying to “win you over”, I’ve only been correcting your innaccurate, idiotic responses & lack of tax knowledge. I could care less if you participate in a tax shelter – in fact, please don’t, ever! You’ll do the world good by staying far away from this industry. Please.

    “Connected with” v.s. “Working for” – Ummm…there are about 5 000 people who are “connected with” COIP. The “top secret” audit information isn’t that secret. There are many people out there who have it. Let me guess – you weren’t on the preferred client list?

    The BS I’m fending off is from you, CC, & a couple others on this forum. Who else did you think I was referring to?

    @ Exflyer – Please read the last month of threads. The CRA has & will always ask for the money back. That’s not what we are discussing here lately. Guess what, I’m still here writing, so you’re already wrong regardless. Please get with the topic du jour and don’t comment unless you have something intelligent to say. P.S. – It’s “quiet”, not “quite” and by your logic, you then must be working for the CRA if you are coming onto this forum to tell people not to do these programs.

    @ Canadian Capitalist: The “warranties” were found to be advantages related to the gifts. These are being promoted by Trust companies who give people stuff for free to donate to charity & claim a receipt. The CRA warns against these programs, but not the programs we are currently discussing. The only tax shelter case that has lost in court is the Klotz & Nash case where the donor was REDUCED to the amount they paid for the gift – the FMV. These new programs are built ON that verdict – that the receipts reflect the cost of the gift. That statement actually supports the validity of these programs, but I wouldn’t expect you to understand why. By your logic, all stocks must be bad if one dropped, so don’t ever buy stocks again. What makes you think that all tax shelters/deferrals/strategies are created equal?

    I sent you off copies of the VERY AVAILABLE audits, letter from Direct Relief PROVING THE MEDICINE EXISTS & WAS RECEIVED, etc. I e-mailed you in confidence, so please respect that fact & do not share my e-mail address with everybody. There are a lot of crazies out there. It would be nice if you also acknowledged receipt on this forum so that these people will know that I was telling the truth.

    If everybody on this forum would rather I do not respond any further, then I’m outta here. I thought I was providing good input based on law & personal experience amidst a sea of illogic & inuendo, but if nobody is getting anything positive from it, then we’re all just wasting each other’s time. Your call.

    @ Cynical – I’ll be back in Canada later this year – coffee?

  217. Canadian Capitalist

    @Steve: Yes, I received copies of the audit and letter from Direct Relief. And I can assure you that I never publish or share private communications without explicit prior permission.

    My point is that the shelter programs in existence in the past were claimed to be completely valid in the past. They claimed at that time that CRA does not have warnings against them. All perfectly true but CRA went after the donors and when the donors lost, the promoters are back with a new and improved tax shelter. This is a cat and mouse game and history shows that the cat (CRA) usually gets the mouse (donors). The point of the original post stands. The participants in these shelters are taking a significant *financial* risk.

  218. Steve,
    Actually your comments have helped me tremendously. Please do not leave this forum especially for hard headed people.
    Can you please forward me at (4friends1972 *no spam* the email you sent Canadian Capitalist in regards to the audit?
    I have invested in COIP 2007 and 2008 and am now going to take a look at Mission Life. I’ve been in contact with Bruce. I also sent him the llink to this forum…

  219. Wow! That’s sure is a rant. Not really worth responding to that point by point.

    Steve said: “If everybody on this forum would rather I do not respond any further, then I’m outta here.”

    I think everyone can guess what my vote is 8>)!

  220. Steve, could you also email me the audit also? dianegp1*no spam*
    I am in the final stages of starting the process myself!!!

  221. Mark Blumberg is the Man! If you could get HIM to say COIP is a sure thing, then I would buy in.

    “If you are buying drugs in India, you cannot say I bought them for $1 per pill in India, but they are worth $20 per pill when they are donated in Ontario and therefore the fair market value of the drugs you paid for last week is $20. How stupid do you think tax court judges are?”

  222. @ Cynical – you’re right, you cannot buy a pill for $1 and say it’s worth $20 and get a receipt for $20. That is how all the older programs work. The new programs that I am talking about have people buy pills for $20 and claim $20. Thank you for substantiating what I have been saying all along.

    Thank you again for proving how little you know about the donation tax shelter industry.

    The sad part is that you probably don’t even know what I’m talking about & won’t be able to figure out.

    So far, I have 2 people saying they want me to stay posting on the forum & one person asking me not to. ExFlyer is still spell-checking the word “quiet” & CC has abstained from voting. (CC – thanks for the confidentially, btw. It’s nice to know that despite differences of opinion, that you are a stand up person.) Feel free, though, to send the Deloitte & Touche brochure to Cynical. I wonder what he will say when he sees the graph of a person’s COST v.s. the donation amount claimed! He’ll have a heart attack! Here is a Fortune 500 company promoting exactly what Cynical thinks is “naughty”. :)

    If I do leave this forum, then what will you people be talking about? I think it would go something like this:

    Person 1: Yeah, tax shelters suck.

    Cynical: Yeah.

    Person 2: Stay away from tax shelters.

    Cynical: Yeah, they are bad. You buy stuff and try & claim a higher price and all the money donated to charity never gets to the charity.

    Person 2: But that doesn’t sound anything like how these programs work. You just mentioned the donation of property, but then said that no cash gets donated. Do you even understand how these programs work?

    Cynical: I don’t need to understand anything. It’s all just smoke & mirrors – trust me. I’m your friend, these other guys aren’t.

    Person 3: I heard they are REALLY crappy. I read about it in the newspaper.

    Cynical: Yeah, they are really, really crappy. Newspapers always present a fair perspective of absolutely everything. Newspapers – cool. Tax shelters – uncool.

    Cynical – take it in stride, my friend. You may not have to put up with me much longer.

    Most of you all sound like nice, reasonable people, but beating my head against some brick walls here is just wasting everybody’s time. Let’s see what some of the other people say before I make a decision…

    @ Anna – I’ll contact you via your e-mail address privately off the forum regarding all the other stuff, okay?

  223. I post articles from respected lawyers who are experts in Canadian charity law.

    You post rhetoric, insults, and bravado. There’s no real info in your last post.

    Not much of a debate.

  224. Steve,

    Sounds great. Can’t wait to get your email:)

  225. well one thing for sure Steve, you and your followers are brutes for punishment.

  226. Steve,

    I’m still waiting for the info. Please email me.

  227. I just attended a Mission Life presentation and have been doing a lot of research. I very much respect the debate on line and hope to God Steve stays engaged in the debate.

    These posts can be time consuming and emotionally draining especially when individuals fail to use logic and instead buy into how they feel.

    Steve, I have worked in private health care in Canada for years. For years a good percentage of the debate centred around what was “legal vs illegal” and here we are years later with choice backed up by the Supreme Court.

    Still the emotional rhetoric around this issue continues to the point its almost not worth discussing.

    I think the same thing has happened on this thread.

    The debate is good and the factual information is better.

    Based on my own research along with reading all threads here it has cemented my decision to participate in MissionLife tax shelter.

    Steve, thank you for your factual information. Thank you to the others who have also tried to be factual and have at least provided for some interesting debate.

    I truly hope Steve that you stay engaged in this forum.

    I would be interested in any of the information you have sent to others like Anna. You can e-mail me at create_it_decor@ *no spam*

  228. I haven’t heard from him yet. If you do, please forward me the info at


  229. Any news from Steve..i haven’t received anything.

    Canadian Capitalist can you please forward me the info Steve sent you at

  230. Canadian Capitalist

    @Anna: Not sure why Steve disappeared from here but I cannot forward the info Steve sent without his permission. Sorry.

  231. Canadian Capitalistno worries I understand but it’s frustrating.

  232. Want to share with you, as a 2007 & 2008 COIP donor only, CRA recently sent me a letter that my 2007 donation is disallowed, sent me a re-assessment that I owe 14K in taxes for 2007. I then filed my 2009 taxes, where I was supposed to get a refund, CRA kept it, and applied it to the 2007 amount that they say I owe.
    My friend, in almost the same position, except that he made a 2009 COIP donation, got back his 2009 refund of over 10K!!! Go figure, even though he was re-assesed for 2007 and told that he has money owing to CRA for 2007, he still received a refund!
    Where is the consistency in the processes and rules of CRA? It sounds like there are none and whomever is responsible to review your tax information, simply makes up the rules along the way.

  233. Don’t worry.
    There will be consistency and fairness.
    They will get your friend too.

    All just a matter of time.

  234. Hi Another COIPer,

    The CRA’s behaviour is normal. They always take the position that they will disallow ALL tax shelter refunds, regardless of whether they are compliant or not with the Income Tax Act, and will come up with an argument to support their position. COIP has always maintained that transparency when they present their program. They let people know upfront that CRA will both audit the participant’s involvement in the tax shelter, and they will always take the position of reassessing to a $0 and ask for the money back plus interest retroactive to the day you received your refund. They also post warnings on their website attesting to the fact that they have disallowed x million dollars of refunds, plus interest. There’s really no mystery here.

    However, just because the CRA takes a blanket position of denying all tax shelter claims, doesn’t mean that the claims are not compliant with the Income Tax Act, which is the law. It is also not the CRA’s job to interpret the law – and all taxpayers have the right to dispute the CRA’s opinion. And the stats are very strongly in support of taxpayers who stand up to CRA, whether the reassessment is regarding a tax shelter refund, or a child care deduction, or whatever. As high as 90% of taxpayers who receive a Notice of Reassessment simply pay it, out of fear, or they don’t want the hassle. Pretty strong incentive for CRA to send out reassessments that may not stand up to a dispute or an appeal, isn’t it? Heck, if I knew that 90% of people I sent intimidating letters to, asking them to send me a cheque, would actually pay me, I might be tempted to do it too!

    AnotherCOIPer, did you file your Notice of Objection (NOO) for your 2007 Notice of Reassessment (NOR)? You have 90 days to do so, from the date you received your Reassessment. If you don’t file your NOO, then the legal defence fund that COIP has in trust with a Toronto law firm won’t be able to include you in their suit against the CRA should they persist in their claim that the tax shelter is non-compliant. Once you file your NOO, the CRA is not allowed to contact you or continue to send threatening letters. Please have a look at this website (totally unaffiliated with me or this blog post) for more information from a firm specializing in tax law

    If CRA does continue to contact you, do make sure that you record the details of the exchange and file it. It could be helpful to the lawyers hired to represent you.

    CRA’s collection department has been known to withhold refunds from later tax years, which makes sense for them to do if you don’t file your NOO. (By the way, you should have received correspondence with regard to filing your NOO – all 2007 donors were mailed this at the end of February 2010. If you didn’t receive one, just contact the COIP office, they will help you.) Even people who have filed their 2007 NOO, if they then file their T1 info too soon after (within about a three week period) may get their 2009 refund “scooped” or withheld. The taxpayer must then contact CRA and let them know they did in fact file a NOO, and request their refund back. Of course CRA must then repay it to you, the taxpayer, plus interest, but they will first advise you to make contact with the Chief of Appeals after 120 days, before they will reissue it. The process is, by design, highly inconvenient. CRA’s mandate is to collect as much tax as possible, and the intimidating and inconvenient process they put taxpayers through helps them achieve their goal.

    What will happen to the disputed tax refund in the long run? Assuming there is enough cash in the legal defence fund (and there should be, by design) it is ultimately up to a tax court judge to decide whether the claim is compliant with the ITA or not. And the current law upholds tax avoidance – please consult the first right in the Taxpayers Bill of Rights “You have the right to receive entitlements, and to pay no more and no less than what is required by law.” And should it go to court, whichever way it is decided, will then be appealed by the side that loses. It can then be expected to be taken again to the supreme court for a final ruling. This whole process typically takes 7-12 years, all of which time you have your tax money working for you, if you have made wise use of it. If the tax shelter is ruled on as not-compliant with the Income Tax Act at the end of the day, then pay back your refund. There is no mention in any case law history that I am aware of where tax shelter participants in well-structured tax shelters have had to pay interest or penalties after the process of working its way through tax court.

    That being said, well over 90% of such disputes settle out of court, and if the tax shelter structure is compliant with the Income Tax Act, the settlements, anecdotally speaking, have been in favour of tax shelter participants. This process of negotiation also takes several years, and again, anecdotally, interest and penalties have also not historically been applied. I received my information about this from a tax lawyer who specializes in tax shelter cases.

    Anna and smartcookie, I’ll be happy to email you with my contact info and help answer whatever other questions I can. Well structured tax shelters are not for everyone, but they are a fit for some. Steve provided some solid explanations, thanks for that.

    And Canadian Capitalist, I wanted to point to your comment on March 8th regarding the company that is selling warranties for another tax shelter program, I would be highly skeptical of their “proof” that interest and penalties were applied to the three cased that lost in tax court – their links just point to more of the same old news stories, not to case law. Remember, they are selling insurance…

  235. Canadian Capitalist

    So, where are all the commenters who were sure that the Orion Foundation was a fine charity?

    The Canada Revenue Agency revokes the charitable status of The Orion Foundation

    “The Canada Revenue Agency’s (CRA) audit has concluded that from January 1, 2005, to December 31, 2007, The Orion Foundation (the Organization) issued in excess of $91 million in receipts for medicine units received through the Canadian International Aid Program tax shelter arrangement. However, it is our position that receipts were issued for amounts far in excess of the actual value of the property. The Organization’s records fail to substantiate that the values recorded on the receipts were accurate, or that the property was actually received, used, or distributed in the quantities reported by it.

    For its participation and tax-receipting abilities the Organization received approximately $1 million in cash. Of this amount, the majority was paid to another registered charity as compensation for its role in the arrangement, to related third party companies as administrative fees, and was also used for the personal benefit of directors. The Organization devoted only $70,000 to its own charitable purposes.

    Our audit has also revealed insufficient separation between the Organization’s operations and the personal business and financial interests of those responsible for its operation. In particular, the Organization has entered into collusive contractual arrangements with directors and related parties who are themselves promoting the tax shelter programs. These arrangements have resulted in substantially all of the actual cash received being diverted into the hands of the promoters and related companies rather than used for charitable purposes.”

  236. 91 million in receipts issued.
    19 million in revenue (est).
    Actual charity? $70,000.

    I’ll say it again. There was virtually no charity work being done here folks. Your just buying receipts at 20 cents on the dollar so you can cheat on your taxes. You know it, I know it and the government knows it.

    Every one of those receipts is a lie and the government has every right to take the money back.

  237. Wow, that was a lot of reading to do. I’m fairly confused by it all. For the time being I’m gonna wait and see if anybody like Steve or Anna come back with any words of enlightenment. I’d like to believe that one can do this, but I’m skeptical.

  238. Can someone tell me what happen now with COIP. Are they being closed down totally by CRA

  239. HoldingOffForNow

    An entertaining and informative – although at times quite repetitive – read. My understanding so far is that the program is 100% legal.. for now. Most previous programs seem to become illegal once tested, which leads to believe that this one is at risk. As has been said, it’s not a matter of “if” the CRA will challenge it, but “when”. They will try to bully participants, but the NOO seems to be a good tool to ward them off. Even if the program is deemed illegal in the future, it would seem that thanks to the NOO, CRA can only recuperate the tax credits from the donations that are disallowed.

    Looks like the upside is that with a little discipline you can keep that money around in case you need to pay back and earn capital gains/interest/whatever while it’s in your hands. In a better case scenario, the lawyers retained by MLF win and you keep everything. If MLF wins, I bet the law will be changed to make it illegal, because as has been said CRA cannot afford the existence of a program that legally allows the participants to save more money than it costs them.

    On the downside, the program is not simple or easy to understand, which doesn’t help to make it feel kosher. I doubt many participants could explain how it works from A to Z. Also if MLF or FAST vanish into thin air before or during the trial, participants are screwed. In my eyes, there is much risk. MLF is in a position where they have nothing to lose, (in fact they have quite a lot to gain 😉 ) and all the risk is transferred to the participants.

    I guess it all comes down to your tolerance to risk, your financial situation and how much you can put up with CRA. Personally, I were rich I’d have a team of lawyers/tax experts/accountants/you name it look at the program and I probably wouldn’t mind loosing a few feathers to CRA. But I’m just a middle-class guy trying to minimize his taxes. In the last 4-5 years I seriously considered but in the end did not participate in two programs, which at the time were legal, signed off by top law and accounting firms. Both programs have disappeared off the face of the Earth and I can only imagine what the participants had to go through or are still going through.

    PS: And I thought I’d just post a few words to get new posts notifications.. Seems it’s hard not to be wordy in this thread.

    PPS: Steve and Andro, please come back, don’t be Shy! 😛

  240. Concern: If tax credits as a result of donations to a tax shelter program like COIP or FAST are challenged by CRA and you receive a notice of reassessment, the issue for most people would be that taxes are withheld (deducted at source). Could CRA simply elect to not pay a refund or hold your money up until such time as an objection filed against a reassessment was resolved in court?

  241. Quoting from CRA website: “Department of Finance had announced proposed changes to the Income Tax Act, on December 5, 2003, to limit the tax benefits from these arrangements.”
    “It is the CRA’s position that the December 5, 2003 amendments apply to these arrangements and will reduce their associated tax benefits.”

    Question: Does anyone know if these ‘proposed’ ammendments have been passed or the ‘position’ of CRA is in fact backed by legislation, or is CRA simply waving it about as blank ammunition in their arsenal to intimidate?

  242. Pingback: A scheme to save 100 percent of income tax? No thanks | Canadian Capitalist

  243. Has anyone actually had to pay the tax man? ie: the 35K mentioned above.

  244. Wow there are a lot of people on here who speak when they don’t know anything about this, especially this Cynical dude. Its simple, go to a Fight Aids, Save Taxes seminar. They explain this in very good detail, they being a fella who was a tax auditor for the CRA for 20 years. Yes you WILL get audited, you being the tax shelter you are in, not you personally. After filing your return, you will become what the CRA calls an agressive tax payer and you will receive an audit notice which F.A.S.T. will help you fill out. This is more of a scare tactic, especially to those who are unaware how to handle the audit, this is nothing to be afraid of. Yes you donate to a charity which buys medicine for AIDS in Africa or Haiti. You take a loan and pay the 4 years of interest upfront. You get a tax receipt for the total loan ammount. How the money is actually used is more complicated but say you owe someone $20000 and the person you owe says that instead of paying him back, he wants you to the money back by buying him 20000 liters of gasoline. You of course say sure! Now you go over seas and buy the gas for 10 cents a liter. He gets his 20000 liters of gas and you get off by saving thousands of dollars to get it. This is sort of how it works to buy medicine. Like I said, before passing judgement, research this more, go to a seminar. This is type of tax shelter is 100% legal but in the end, its simple, if its not for you, don’t do it.

  245. If you live in the Toronto area and have participated in a charity tax shelter in the past and have been reassessed by the CRA, a CBC reporter is interested in speaking with you. Contact me and I’ll put you in touch with him:

  246. i plan intaking part next year.. my dad did this year.. i have read this from 2 times now.. and boy is their a lot a stud replay buy some unamed people….however steve it be nices to see another comment yet by you on here.. ill probly reply again. i would like to get a hold of all some of those emails people been talking about… i guess i need to scan thre one more time.. cause i cant rember right now what onces i wanted…. i read this article back in july.. after going to those semminares.. and ive been to 4.. very informative…it was nice i went with my dad to his meeting with one of the guys.. we had a 3 hour conversation.. cleared a lot up… then im impressed .. i told him i was on ei for this year.. and might consider for next year. when i get hired again..since im in a construction trade.. they still said ya sure come down.. i brought my girlfreind.. and we had another 2 hour conversation.. i convensed my girlfriend half way.. un fortanly she only learned what she knows from me.. and missed the first 3 semenares. but said .. this guy helped her to understand it better.. so i guess i have more semminares to go to..get her on board. i cant really do this with out her suport. well i could. but i rather have her on board now.. then try and get her on board later…lot of the doctuments posted by cynic just suport what i was told the cra would the seminars and by steve….. i also love the one where some posted that coip is in trouble… i read that…. THE CRA SAID MANY TIMES IN THAT ARTICLE IN ARE OPION>>>>>> reinforsing the fact that the cra though is disalowing the donation, and recalling the money.. thats based on their opion… how is it so many canadains see a CRA’s opion and go on no he belive s in his opion i owe hime 10$…. if you give a teller $20.00 they sometimes make mistakes and say you only give them $10.. do you right away say your right. and give them $10 more…NOOO you look in your wallet.. and double check.. and make a fuss.. if your honest and know their wrong.. its a hard to win sometimes.. and that what the cra is hoping you dont want to fight that battle… and yess i know this isnt a good example…..anna hurd anything since you filed your NOO on your reassement? o but i do have a great example you can choise to belive me if im not.. ture story happend to my dad my numbers might not be exact.. but it proves the cra dosnt charge intrest while in court…. ok so back in 1989 when i was 4 years old. my dad worked for the airlines.. they sent him up to rankin inlit( back when it was still NWT) not Nunavut like it is now… we moved to yellowknife (capitol of NWT) in 1991 they transfred him yet again.. the goverment was debating a law back in 89 about how if you live in housing supplied by your employeir it should be taxed.. damb them taxing everything agian.. anyway so they passed it in 91.. and back dated the tax rulling .. my dad gets a notise of astment in 92 0r 93 that he owes $29,000 in back taxes due to the fact he didnt pay any on that nice house the airlines supiled.. now heres the thing is my dad was make not much more then min wage.. and in rakin in 89 milk was almost 4$ a litter based on the fact you could only fly things in no roads in or out.. the cost of living was overinflated.. we were given a coupany house to live in 2 bedroom nothing fancy.. but they thing cost $4000 a mounth plus utilities ( bassed on the fact the it was being rented to that company) so my dad said woa wait a min.. that is unreasonable…i wount pay im taking this to court.. Noo was filed…so my dad desbustes .. he puts uses the tax law that say you cant cause undue hardship… and this amount is very high.. they siad how is this high prove it…1.. cost of living is higher in rankin then the avrage candian city or town, camparied to wages 2. their is vertually no renatle housing aviable.. so they can charge outrages prices, 3 my wage would have never cover the cost of those bills.. they say yes sir you are right… however thought this may be undue hard ship, we cant make exceptions for one person, so what we can do is use what you used to to defend your case. yes it is high then the avrage. so we will base this amount off the avrage for people with that wage ect…. so 3 years in court a juge ruled the amount be reduced from 29K to 14K still high but less then half` and didn charge him intrest or fees so in 97 he had to pay.. proving that while a their is a descion being made you are not charged intrestes and fees… it would make sences too.. because you have right to object, because they can make mistakes.. or over charge… so why should you be penlized for for using your right to object, a reasonable cause… witch is by the way. that i used my loan/ credi card to by these pill worth x dollars.. and the money i get back i invest with pay off morgage sitmulate the economey save lives in africa. just thought i thorow that out their

  247. sorry for any spelling or grammer issues. it is very late

  248. Hi interesting stuff, i enjoyed your post. Yes people are scared. to be honest it is always on the back of my mind and yes i will fight the CRA. I will not settle nor pay a dime unless this is final. I have not heard anything back from the CRA since sending in my NOO.

    I wish steve would come back just to answer some additional questions i have….

  249. I just received a form letter from COIP/PanAggregate that asks me to pick one of four options regarding my interest balance and applying it to the purchase of pharmaceuticals. In reviewing the document it looks like the preferred option is Option 1. Just looking for some direction as my accountant is on vacation. Not planning on acting before then but just curious if this form has any hidden role in all of this or if it’s just the final step in settling the loan agreement. I was a 2006 participant if that makes any difference.

  250. I just realized that there is another “Steve” posting on here who evidently gets a lot of mail. I’m not him lol. I will change my screen name to Steve D so we don’t get confused.

  251. so steve D you took part in coip for 2006… how has the whole process been? and the CRA what did they do if anything?

  252. The whole process is pretty much as described. In a nutshell, CRA has disallowed the charitable deduction, COIP has filed the NOO and now we wait. I was sent my notice of reassessment and have paid back the tax savings. At this point I am out the cost of the original investment in the program and await the outcome of the legal proceedings. I chose to pay CRA to avoid the interest penalties that will accrue if the NOO fails. I have had reviews with them before and where I have won, they have paid me interest, where I have lost I pay them. There is no getting around that and any fantasy about a loss being handled with pennies on the dollar is a fools dream. Also, you have only one account with CRA and you carry the balance owing forward. If you are making monthly or annual remittances for your taxes or in the case of a possible refund, CRA can, will and have taken these ammounts and applied them to your total owing ie. what they believe you owe them from the disallowed COIP program. Ultimately, it is my hope and belief that the NOO can be successful if in fact they have sufficient funds to mount and continue the legal fight. I do also believe that if we are successful, the tax act will be changed to specifically disallow any future programs of this type.
    Anyways, just my experiences and thoughts.

  253. so when you say you paid back and “out the cost of the original investment” are you talking about the loan to get the tax credit is the amount your out?(meaning you paid back the tax credit?) so why did you pay back before a court decisson is made? my dad had fight with a CRA and no intrest was charged well they made a i posted earlier..with the NOO being filed, CRA can still take whats owing out of next tax season?

  254. I did not pay anything as I have the funds locked in for 5years. So far in history there has been neither interest nor penalty charged back. They only start to charge you interest once the case has been settled and you don’t pay on time. I’ve done my due diligence! I also think that COIP will fight and if we do have to pay back it will be very little.. I spent lots of time researching tax shelter before i made adonation and COIP was the way to go.

  255. ok that make more sences now… cause i been dooing a lot of research my self, and the mission life and fight aids… seems very well structured…as far as i know coip is no longer offered in 2009… what i was told by a fast track employee.. the reason for the change in the program, was to fine tune it to newer tax laws, so that they would have a program to offer still complaint with current tax laws.. i asked him how this would effect coip. i was told it wouldnt, because coip was complaint befor the change. i had two meetings with fast track employee’ was just to tag along with my dad..when he was enquireing.. and i meet with a diffrent guy.. i can only rember one name, marcel. they seem like they know what they’re talking about.. and i looked around the net, and havent found any negative feedback from a person who “””has taken part in thier program”””… i also noticed that Darren Weeks was on the news just before the 2010 vancover olympics.. he had purchesd (or sponsored) the candian bob sled team for the next 5 years.. i’ll also be attending two more seminars, this week and next pretty sure my minds already made up about partaking in fight aids, i appricate your help and answers anna..

  256. If you lose in court you will pay interest and penalties going back to the year assessed.

    Three things to ask yourself before investing, intresting stuff.

    1) Have you talked to a Chartered Accountant or tax lawyer about investing in this?

    2) Has anyone ever won in court with this type of arrangement. If not, why do you think you can?

    3) If you don’t understand simple things like how to spell words like interesting or sense, how can you understand complicated matters like income tax law?

  257. ill look into intrest and penalties from a loss in court.. before i comment on that

    1) i’ll look into a charter acount scam hater.. thank you

    2) another great question is why have not all tax shelters gone to court? CRA cant aford to lose(or else all candians would partake)
    Im looking for the 5 to 14 years of intrest free loan to invest with, if the rich can do it, why cant i (or us liitle guys)
    3) i may have a weekness in spelling, but that dosnt not effect my ability to understand.. if you choces to belive me or not, no need to make the blog a fight of persons abilitys

    but thanks for the questions

  258. Intresting (sic) Stuff:

    Some tax shelters don’t go to court because they are legitimate, thus the taxpayer is allowed the deduction or tax credit. The charitable donations ones are reassessed because they are not legitimate. The taxpayers can choose to file a notice of objection, and then take it to court. It has nothing to do with Canada Revenue Agency not being able to afford to lose.

    What I was saying is how many of these type of arrangements have won in court? Canada Revenue Agency usually wins.

    Speaking of court, I see here that a major class action lawsuit has been launched against the Parklane Group for the losses its investors suffered. If this sort of tax shelter was legitimate, would that happen?

    Some of you people might want to contact Sam Marr and join the lawsuit.

  259. I have had a CRA tax shelter review in past which disallowed part of the credit which I had received. Yes, they want interest from day one and not just from the point at which the decision was made. They wont be giving anyone an “interest free loan” if the shelter is found to be flawed in a tax court. You will pay tax effective from the date on which you wrongly received your credit (in theirs and the courts eyes). As I’ve been through this I chose to pay them back while this thing plays itself out in court to avoid those interest fees. If we are successful I expect to receive interest on the money they have withheld from me. I have received interest on debated amounts in past where I have made my case successfully. To Anna, I appreciate that you feel you have done your due diligence but if someone has told you that you will pay “very little” back if the case fails, then you have been misled unless you consider the total amount of the tax benefit received as being “very little”. This isn’t bankruptcy court or something. You will be required to pay what you owe. You may not want to hear that, certainly I love your take on things, but it doesn’t work that way in the tax system. Even bankruptcy cannot totally protect you from the tax man. Again, hopefully all works in our favour and I’m glad to hear you have your credits tucked away in an investment that is hopefully gaining in value enough to cover any interest that you might eventually be liable for. If it’s a good investment, even if the case fails, you may be up a buck or two.

  260. We are not talking about Parklane. Our discussions are about COIP. COIP is a totally different structure.
    There is no need to insult anyone. We are hear to exchange thoughts and inform ourselves on COIP and Missionlife.

  261. Steve D. Which tax Shelter did you contribute in the past that you had to give back part of the credit you received? I am assuming I will have to give back around 30-40%. My friend also donated to a tax shelter and she had to give back 35% with no interest nor penalties. It was settled out of court.

  262. Just to clarify, to be up the “buck or two” I alluded to, you would need to make back not only the possible interest penalties but also enough to cover your initial investment which is lost if the court case fails. As most COIP/Orion investors invested about 10 to 15 thousand in the program (original cost for 8 to 10 units plus Orion foundation donation) you need a pretty good investment to make up that loss with the twenty-five to thirty thousand that you received in credit. I’m not saying that it’s impossible, just that you really need to have some great investments.

  263. I can not believe the ridiculous conversations in this thread. Everyone seems to want something for nothing and is astonished when they are called on it. Don’t give me that “charity” crap. What people want is to put $1 in and receive $4 back, justifying it all by saying they are really just being philanthropic. I like to pay less tax as well but I sure don’t get caught up in this bunk. Don’t be surprised when the tax man has at you.

  264. The legislation seems to revolve around the assumption that no gift will be made:
    “Furthermore, as indicated above, completed audits have shown that there was effectively no gift being made in many cases”.
    My question is: what if a gift IS made?

  265. The final word on why the supposedly bulletproof COIP and FAST are destined to be doomed.

    CRA ruling on COIP tax shelter:–charity-closed-after-bad-books-revealed

  266. @Eric: Thanks for the Toronto Star article. I guess that the old saw about if it’s too good to be true, it probably is applies in this case. Incredible that CRA says that just $10,000 out of $91 million seem to have gone to charities.

  267. Our law firm has commenced a class action for tax shelters that operated by means of leveraged donations, which in turn resulted in reassessments disallowing those donations.

    See .

    Give us a call on the general line if you’d like to speak about your CRA dis-allowance resulting from this or a similar tax shelter, or to my direct line at (519)561-6257.

  268. IF you pay TAXES you must read this book, The TAX COLLECTORS Bible is written by Alan Baggett a former CRA tax collector who after 8 years of working for the agency got so disgusted with his job and his colleagues criminal behaviour that he decided to resign and write this tell all book exposing CRA limitation and empowering the tax paying public.. The book contains over 400 pages of information the CRA does not want you to know. After reading this book you will never be afraid of CRA again. Here is a partial list of some of the things you will learn in this book. I couldn’t stop reading from the moment I picked it up.

    How to defend yourself from CRA’s Criminal and Unethical practices

    How to access the CRA’s secret files on you!
    How to audit the auditor

    Being audited? Learn how you can audit your CRA auditor

    T4 Horror stories – told by CRA employees

    How to Protect your assets from an overzealous tax collector

    What to do if you get Reassessed

    How does the tax collector locate your assets

    Can the CRA search your real property

    Learn how the CRA can saddle you with your neighbour’s tax debt
    How to get certain tax debts written off.

    Happy Reading

  269. Pingback: Budget 2011 Cracks Down on Abusive Charities | MoneySense

  270. it’s true; many programs out there are probably “Scams” but remember there are very legitimate tax shelter programs that have been running for years that really do promote a “loophole” or strategy for their clients.

    Think people! – Tax avoidance programs are very LEGAL but display virtually no advantage to the CRA and their “business”. The CRA like any business has an agenda; now imagine if your business depended on the public paying their taxes, you will do anything in your power to make any program which gets in the way go down. And trust me the CRA has the money to do so.
    Remember tax shelters are legal for a reason. But make sure you RESEARCH extensively and choose a legitimate program. I’ve spoken with many agents from various companies on such programs and all offer various packages. I’ve been in talks with “The VIA Project” ( one because I was referred by a friend and second it’s close to home.
    Do your research, and choose a program right for you; don’t believe everything the CRA tells you. Focus on the LAW. 

  271. Contrary to what Mr. Jovicic says, tax avoidance programs are not legal. The General Anti-Avoidance Rule (GAAR), set out in Section 245 of the Income Tax Act, makes a series of abusive transactions arranged primarily the tax benefit illegal. See . People are allowed, however, to legally arrange their affairs in a manner than minimizes tax.

    This Via project looks like an attempt to sell art, but probably not a scam. I don’t really see where the big tax advantage is, nor do the promoters provide either a projection claiming such, or a legal opinion from a reputable tax law firm. I am concerned that the promoters don’t include a reputable CA or tax lawyer.

    Why not just donate stocks or mutual funds with a gain to the charity of your choice? You will not be taxed on the gain, but get the full value of the proceeds as a tax credit. Of course you would be further ahead to keep the proceeds yourself, but if you are the type of person who makes large donations, this is the best way to do it.

  272. @Canadian Capitalist
    How does one get out of this loan agreement thru mission life financial once the paper work is signed, less than 15 days ago?

    Please email me at netsirc-at-hotmail-dot-com thank you

  273. Hello all,

    I’d be happy to help or answer any questions involving Tax Shelters or the specific programs of Mission Life and GLGI.


    I do work for Fast Track.
    I don’t care weather or not you participate.
    I do care about making sure you have accurate information and expectations.

    From some of the comments I think some people have the idea that the CRA has more power then the CIA, FBI, Delta Force and The Justice League combined. They are just a government agency, like any other, and they rely on the fact that if you want to fight them you are looking at a $200,000 (minimum) court battle, pretty heavily.

    Mission Life is properly structured 3rd Generation Tax Shelter. Is participating a risk, yes, so is crossing the street. Is it a gamble, no, while we don’t know what the eventual court decision will be, the programs follow the letter of the law (CRA’s opinions are not Tax law, and are not unbiased).

    Each person must decide how to arrange their own finances, I don’t begrudge anyone who doesn’t want to
    participate is a Tax Shelter. I do think that the Richest Canadians use Tax Strategies to save or deffer Taxes to their advantage and I think we should do the same.

    Thank you,

    • @Khalid: It belies common sense that those of you promoting tax shelters would still be claiming that these donation schemes are “properly structured” when so many have either been (a) challenged and won by the CRA or (b) proven to outright frauds. The simple fact that a $1,000 donation generates a $4,000 receipt is enough of a red flag. It was a big red flag with Fight AIDS Save Taxes and it still remains a big red flag.

  274. Canadian Capitalist, You are absolutely correct.

    It is impossible for a $1000 dollar donation to produce a $4000 donation receipt. Anyone who tells you that can happen is lying to you.

    In order to get a $4000 donation receipt (and therefore a $2000 tax credit, in Alberta) you would need to donate $4000. A donation receipt must follow this formula:

    $1 in donation (Cash or Property) = $1 Donation receipt

    If you make the donation via cash, credit card, line of credit, property, or financing it makes no difference.

    Some tax shelters are challenged in court, those that are not properly structured lose, usually very quickly. Those that are properly structured usually settle, neither side wants to risk losing, an indication of a properly structured Shelter is how long CRA takes to take them to court.

    Some Tax Shelters have lost to CRA, but unless you read the actual court decision it can be hard to tell what actually happened. For example one of the GLGI donors was taken to court, CRA didn’t have its act together and agreed to a “Consent to Judgment” which favoured the donors totally (as in no repayment). However as this case was not argued in front of a Judge it does not set any precedent. CRA spun that one as a victory as the donors “Consented to Judgment”.

    From the COIP program the 2006 donor that filed Notices of Objection in 2009 have yet to hear anything from CRA (If anyone has please let me know so we can get you the proper help).

    I am always happy to answer any questions you have. I enjoy talking about these subjects.

  275. That’s fine we don’t have to rehash anything. I don’t want to even try to change your belief that Tax strategy’s don’t work.

    If anyone else has any questions, or wants to have a discussion I’d be happy to engage them.

    I would like to point out though that both Tax Strategy’s that we offer have a standing reward of $10,000 to anyone who can prove that they are not compliant with the Income Tax Act. You would think that those who oppose these programs would be lining up to prove that don’t work and collecting a nice bounty in the process.

  276. Please send me your contact info –4friends1972@

  277. Registered Tax Shelters= losers ( voice of experience) promotors pocket the money. Note the pattern they start a new one every three years after theCRA audit for the next group of suckers You can’t say you were not warned. You think paying tax is expensive wait til you been reassessed, not to mention the sleepless nights.

  278. The cra is complicit in these scams. They should stop pretending that they are not. They collected at least $40 000 in interest from me alone and I haven’t finished paying them back yet.

    The cra could easily shut all these schemes down simply by requiring that all of them be approved first before they are allowed to go to the public seeking donations. They could at least push for legislation requiring such. They don’t because the schemes are every bit as much a moneymaker for the cra as they are for thre promoters.

  279. Aw, taxtrouble…Why so sad? You sure were all smiles and chuckles when you got that big refund! Telling all your friends about how you beat the tax man. Funny how the story changes. Now its all his fault.

  280. Khalid, whats your email address, I would like to get in touch with you?

  281. A friend of mine has made a donation to this charity “Fight AIDS Save Taxes” through the Fasttrack Group. He has received a Tax refund of $40,000 for the past 3 years. The CRA have NOT touched or questioned these Donations. The Charity is a Registered Charity as well.

  282. I also made a donation to COIP, enjoyed those nice big refund and now I’m paying every cent back. Let him enjoy his money until he receives his notice that he owes $100k. I have to pay back $1000k ($50k is interest and penalty). Not fun and stressed out..looking at doing consumer proposal and having to start life all over again. This is my fault and I have to deal with it… help your self and pay it back before they ask for it. It will save you a lot of headache. I was greedy and it cost me twice as much.

  283. Correction, that’s $100k not $1000k. Not much to say, except greed will get you know where. I did the appeal, reduction in payment, etc. Still waiting to hear back. I can wait for the appeal and see what happens but I don’t want to wait another year (interest accumulating). I just want to get on with my life and pay this loan off. I’m a single dad now and now I have to get a second job just deal with this.

    I saw similar situation few years back when others were in my shoes but i didn’t take the advice instead I waited for CRA to come and crucify me.

    Do your self a favour and pay it back.

  284. I donated to COIP and i heard nothing yet. No news from CRA..

  285. Are you sure you did everything right… joshi04
    … Did you file your notice objection before 90 days?
    Also being you’re the only one with a recent coip problem makes something sound off.
    Not to say you’re lying.
    I notice your calling it an appeal
    It should be NOO
    Notice of Objection … filed within 90 day of re-assement.
    If you miss that date the shit could hit a fan

    From experience threw my dad, who took part
    You donate threw a tax shelter.
    Getting a tax shelter number attached to your donation.
    Receiving a recent from the charity, after the tax shelter donated goods and/or money,
    Your receipt is obtained from the charity once goods and/or money has been received by a charity.

    Please don’t mix tax shelter and charity’s mixed up, theirs enough confused people on here
    Tax shelter is as simple as RSSP or TFSA
    Or other avenues such as COIP, FIGHT AIDS, and a 3rd one that starts with a G
    It’s a 4 letters,
    I use these, because their ones I’m familiar with and researched, find nothing at felt wit so far except other than this form of confused people arguing back in forth, witch I started reading back in 2010

    Anyway it’s late and I regress

    1. You donate threw a tax shelter.
    Getting a tax shelter number attached to your donation. After doing some due diligences

    2. Recive a recent from the charity, after the tax shelter donated goods and/or money,
    Your receipt is obtained from the charity once goods and/or money has been received by a charity’s

    3. Following year during tax time file your taxes and summit your donations not much different then
    Say giving $20 to Salvation Army. But you also summit your tax shelter number with.
    File in standard snail mail, approx. 4-6 weeks

    4. receive your refund from the government, for helping others like aids suffers, children who don’t have computer education opportunities, or meals for children, things government won’t do, but wants you too, were Canadian after all they have an image to up hold, on the principle you have plans to stimulate the econ, by investing in companies, via stocks, or anything you want do to invest with.
    It takes investment capital to build things after all… or use it more personly to hire more staff and grow your bussines suppling jobs, and furthering your business, imgain having more of your money to stimulate the economy in your way, something that you can get your money back easly if need be. I’m not talking a car or beer. You loan the government extra tax money every year interest free… perhaps file for a T1213 or is it a T1214 request to reduce tax at source, from your paycheck aka source… for those dudiligent RRSP filers.

    …. And by the way a TAX SHELTER is to help those who have a bit…aford more to save for ie. Retirement by reducing their taxable income now (SHELTERING), why else do you put money into RSSP’s for. So you get a bigger rebate this year, have more money for retirement…pay more taxes later aka. After retirement…., and since taxes go up, you know later… you will pay more taxes then now on that money… and if it made money in the goverments RRSP (AKA tax shelter) they get to tax that extra money…
    Just like they hope for in people doing non-government tax shelters… like shuch heavly debated names like COIP.

    Hmmm RRSP registered… (Just like all tax shelter are) retirement savings plan

    ALL Canadians are allowed to take part in tax shelters,
    The government issues tax shelter numbers
    For its registered tax shelters,
    Or private tax shelter (COIP lets use them for example)

    But it’s not the government’s responsibility to tell u what tax shelters follow the tax laws
    Which by the way is 3300pages thick updated every 6 months.
    .. But they do let us know what ones they found and charged in court to not follow the laws
    All I have to say is donating paintings and you should know what I mean.

    And in those pages you have a bill of rights,

    Right to object… is one of them
    Right to not have to pay fees or interest until a design is made… (Must be made by a judge)
    ….. (NOT THE CRA)

    That is my main point…

    If you filled your NOO… Notice of objection

    And being the CRA is an option, and their option is always you owe more, cause they get a bonus… if you pay more, even if you dont have too.

    Which is against one of your bill of rights in the tax law… witch that right is…
    You don’t have to pay more tax then you are required.

    Yet the CRA operates on a principle… if they can get you to sign a check, by scaring you with fee or intrest, that cant be inforsed until… a judge makes a desion… aka …a impartial desion (another bill of rightsin the tax laws)
    So if you follow the paper hoops properly… the CRA opion can’t hurt you
    You can always say NOO to an option

    Which brings me back to…

    1. You donate threw a tax shelter.
    Getting a tax shelter number attached to your donation. After doing some due diligences

    2. Recive a recent from the charity, after the tax shelter donated goods and/or money,
    Your receipt is obtained from the charity once goods and/or money has been received by a charity’s

    3. Following year during tax time file your taxes and summit your donations not much different then
    Say giving $20 to Salvation Army. But you also summit your tax shelter number with.
    File in standard snail mail, approx. 4-6 weeks

    4. Receive your refund from the government

    5… 90 days later the government denies all and re-assess all tax shelter participants
    …. Even though you’re aloud to partake, your auto re-assets… meaning you always get a letter from the CRA saying you owe back the refund check you just got in the mail.
    .. And the letter should say basically… we have re-assest… and we are dening your donation, because in are opion you Tax shelter dosent follow law… (Because we don’t tell you what ones follow, we assume none do, we want proof)

    6… you File your NOO… (Notice of objection)

    7… CRA send a letter … we received your NOO, your reassessment has been reduce to 0, until a decision has been made…
    By the way what interest times 0… Its 0…

    8… CRA send you a questionnaire to fill out…

    9… you wait for the decision
    Be it 2 years, 5 years, 13 years… you wait…

    And all the while you don’t be greedy and you invest
    Make money pay taxes on your capital gains…
    Employ people who pay taxes

    By the way… @ joshi04 being… COIP. Hasn’t finished the court hearing, CRA said… in openning, it’s the CRA opion that you didnt delivery any goods… COIP said here is paperwork we loaned money to our clients, which was used to purchase the goods… here is the receipt…
    The goods were then delivered… here is the bill of lading…
    After COIP presented their documents CRA said to the judge we need more time to prepare their case. It’s been granted over and over again, the CRA still trying to put together a case…
    So an impartial decision hasn’t been made by a judge, for this tax shelter…

    … So I’m not sure what makes you different. That you have the CRA saying you owe,
    Cause once your file your NOO
    The CRA files the NOO to the case and then makes a decision on COIP as a whole not the individual…

    Plus being you had received 100K
    Based say on Alberta who gives the highest rebate on donations… at a tax credit of 50% on every dollar over $200.00
    I know for a fact you had to receive a receipt for donating 200k

    You would have to put in 40k to 65k to get a receipt of 200k
    So will say 52k to place it in the middle

    So being that is actual expense,

    …. Even in the case of the paintings
    They subtracted the initial cost of goods from the rebate… because those actule goods were donated

    Witch would mean you owe 100k – 52k…= 48k owing

    Also for someone to get 100k back
    .. Theirs a few other things I know

    In 1996 the max a person could donate was increased from 20% to 75% to your gross annual income (also ask me to question why we can now donate more government???… Sounds like they want us to donate more)

    Meaning if you gross was a 268k you could donate 200k and receive a 50% credits on the 200k… giving you tax credits witch could be reinbused to you as 100k in you rebate

    So if you were able to put 40k or 60 k of your 268k grosses income
    Like I said middle for the sake of numbers
    If you put 52k… of 268k
    Witch got you back 100k

    And you didn’t blow you 100k… you could easly pay back 48k
    Or if you raised 52k of you 268k
    What’s stopping you from raising another 48 k now…
    And yes you do sound greedy… and lets not blame you miss filling, miss understanding
    Over spending
    And greed… on coip… a company who is trying to make
    Tax shelters more affordable for people who don’t make 268k a year

    But at 2k at a time rather than 52k…

    Buts as with the CRA

    That is just MY OPION
    I’m not an expert; I’ve just done a lot of reading for the last 2 years
    Witch you should have done, if you threw 52k at something
    Do your research…
    And don’t try and sound all like you got a hart sob story…

    And I approve my message, with all its grammar and spelling error

  286. no personal attack eather, ive just wanted to comment for a real long time

  287. What's happening now?

    I would like to know if anyone else has had to pay Revenue Canada that made past donations?

  288. I’m wondering if anyone else that has made a donation with COIP, faced consequences with the CRA?

  289. I filed my notice of objection and heard nothing from the CRA (4 years)..i guess time wil tell. I will not pay anything until back until this is all over with..

  290. Has anyone recently received a letter from RLG asking for the interest payment for the next three years (for the 2008 tax year)? Also, any info regarding a possibility of RLG making us pay the full “loan”?

    • TO Dejan
      I received a similar letter from PanAggregate/COIP

    • We recently received what I call an extortion letter from RLG. I can’t imagine paying them more money could be the answer especially when their Charity HEEDAC has had it’s charitable status revoked by the CRA. We did get cold feet and have completely paid CRA taxes etc. Any new info would be appreciated

  291. Anna,
    A friend of mine run the Tax Shelter Exercice with MLF and Last week he got a 30 pages document from CRA disallowing his donation claim in 2009. What Next, What is the procedure ? What he needs to do ? Advise.
    Many Thanks

  292. Did anyone received letter from PanAggregate/COIP after 4 years into donation program that the prepaid interest has ran out and that they want the donor to pay another 3 years of interest?

  293. Nope! That’s crazy! I asked many time and they always said its unlikely!! I guess we should of read the contract carefully!! How much do they want?

  294. I paid CRA back what they claimed I owed them when the inital COIP claims were disallowed. Also filed a NOO. Was advised to pay back to avoid interest penalties which could possibly be effective with 2008 (the year I used COIP) and not with date of decision, ie. you will owe interest on the money you have wrongly held for each year since the claim was disallowed if the decision goes against you, in my case since 2008. If you pay CRA back and the claim is eventually allowed you will get interest on the money they wrongly held from you. I didn’t want to take the chance of incurring ridiculous interest penalties if the whole thing fails which unfortunately I believe it will given COIP’s internal, management and structural problems. At this point I don’t believe that there is any “legal” team making our case and tend to think they just took the money that was set aside and hit the road. Hope I’m wrong but I doubt it.

  295. Are you the same Steve in the above thread swearing the program works?

    • No I’m not the same “Steve” but imagine my surprise to find out that there is more than one “Steve” on the planet LOL

  296. Haha! I actually am doing the opposite. I have 3/4 of the money I received in an investment.
    I will only pay back once this whole thing is settled! I havent heard of any tax shelters that paid int and penalties. They settled with CRA. Yes they paid some money back not all!

  297. The amount you pay back depends on the decision CRA reaches. In some cases there will be a ruling where the entire amount will need to be repaid while in other cases CRA has not eliminated the claim but has reduced the amount that can be claimed as a write-off. You may end up paying it all back or a partial but you will definitely be charged interest on any amount that they dictate need be repaid. I haven’t seen any exceptions to this. In this case I don’t believe there will be penalties however if the ruling rejects the COIP tax shelter claims. CRA is not in the business of giving tax payers interest free loans on money they should have repaid hence the guarantee that interest will be charged on any amount that they dictate we owe them.

  298. I have also recieved a simillar letter as Dejan and Aleksey got from RLG. In the letter they are asking to pay interset to pay for the next three years (for the 2008 tax year)? Even we never lend any cash money from this organization. What should i do please anyone help me to resolve this….

  299. Yes I got the form from rlg too. Plus another note stating WE must replenish the medicine too now. If we dont then they WILL go after us in collections. This is so screwed up now. Collections will prob sue as its a big amount and of course kill our credit ratings. Thereis no way we could possibly restock this medecine our selves.

    I am not sure what to do at all .. freaking out

  300. Hi Aleksey. Dejan, I did. PanAggregate financial sent letter and tell me pay the interest for next three years. if you pay them now, what is going on after three years they want you to pay back the load are you going to pay them? How many more donors received the letter /

  301. Has anyone paid the additional interest that PanAggregate is asking for? Did you get another letter from them saying if we dont pay that they will take the matter to collections agency?? What are you doing about it?

  302. I haven’t had anything to do with these schemes but Carmen if things are going south with this company I would advise not paying them any more money. The collection agency threats are probably just threats, and if even if they aren’t you’ll just have to contest the extra interest in court

  303. I also strongly recommend not paying them anymore interest. Interest was paid upfront in the initial contract. RLG and COIP seem to be attempting a cash grab to recuperate as much money as they can with legal threats and intimidation.

    The RCMP Criminal Investigation Program is investigating over 40 tax sheltering promoters (
    I strongly suggest that if you have been hit by this tax sheltering scheme that you contact the RCMP Commercial Crimes Sector and make sure they are aware of your situation. The more complaints they receive from Canadians the more urgency they may pursue these promoters and hopefully put them behind bars.

    Does someone know of a Facebook group created so we can unite our information? This is not a battle to be fought alone.

  304. SIR,




    • Hey David…interested to hear your experience on this as I am involved with fast track too and starting to get a bad feeling about this.

  305. If there is a group, please let me know

  306. I have contacted the CRA Informants Leeds Program (1-866-809-6841) and reported all my documents and communication I’ve had with RLG. I HIGHLY suggest you do the same. The more Canadians we get reporting their information the better the chances of this leading to criminal charges and their operations being shut down.

    Be careful of letters sent out by RLG. Do not sign any more documents or even communicate with them. These people are nothing more than criminals trying their best to appear credible. Their operation will not hold up in a court of law.

  307. Is there any group out there to help all participants in coip, missionlife and pgi programs. It sounds like something go south. I have heard that all three program operated by the same group of people. Anyone know anything about this?

  308. Anonymous Canada


  309. Anonymous Canada

    The yes is for both, just perhaps not the answers you might expect. If you are comfortable, leave an email address.

  310. Anonymous Canada, my email is Please email me information on help for participants in these donation programs. Thanks. Hope to hear from you soon.

  311. We also got a letter stating they wanted interest for the next few years, I call Pan Aggreate and the lady who answered my call put me through to a voicemail for a Dahlia?? or similar name and that was last week and she didn’t call me back. I won’t be sending anybody any money soon!!

  312. Please send me email too Anonymous Canada.

  313. Please send me email too Anonymous Canada.

  314. Please send me an email to anonymous Canada

  315. I would appreciate if you can email me too.

  316. COIP/Pan Aggreate want a settlement to finish the loan . Apparently the remaing loan will be taken by another pharmicuticle and I need to settle for $$$ andI will be debt free!
    Never heard of this company and no info online?

    Anyone get this letter today??

  317. Is there a way to be contacted about MLF without leaving an email on this site? We have just received documents from the CRA advising us the ‘donation’ made for Fight Aids, Save Taxes has been disallowed as it is not a valid gift. Thank you.

    Any thoughts on a class action suit? I thought we had done our homework. Contacting the MLF office tomorrow.

    Thanks for all you posts. Very informative

  318. Don’t pay anybody anything. It’s a scam being perpetrated by the same group of people. Class action makes sense. We should be going after the pre-paid interest on the non-loan.

  319. Did anyone else get a bill for options to pay the loan interest from SUNRx for 835.27 to settle the account on your debt obligations. I have tried to contact coip and not to my surprise there is no answer.

  320. Anonymous Canada’s advice was to walk away from it. People behind these programs are not good people. Has anyone got email from COIP or Missionlife mentioned other groups (Profitable Giving Canada and Justice Trading) and advised donors not to listen? Has anybody had knowledge about Profitable Giving Canada and Justice Trading?

  321. Not too sure you can just walk away! I you did sign for a lian! agree that the options that they give you aren’t kosher and its against the contract you signed! The loan is suppose to be paid back in pharmaceuticals! Not cash!
    No clue what to do!

  322. Sun Rx is not a real company. You can check Dunn and Bradstreet, do a NUANS check or whatever you want but will find it’s a scam. These people are operating from virtual office addresses in Toronto and elsewhere. There are no real businesses or legal teams working for COIP etc. , at least not on our behalf. I would suggest settling with CRA and possibly organizing to go after the principals at COIP and associated businesses (they are all the same people) and see if there is any chance to get back our “prepaid interest”. Don’t respond to any requests from any of these people at this point is my advice.

  323. I agree with Steve. BUT you signed a loan and they can come after you. I think i will start looking to replace the pharmaceutical and return them to PanAggrate , so I can follow what I’m supposed to from the loan and hope I am following the law with the CRA.

  324. Oh man! They got you all coming and going…. They got everyone so distracted with questioning about what the CRA would or would not do that everyone fails to see the house of cards upon which the whole payback scheme is built. The irony is that the CRA part of this is the only legitimate and truthful part. You file you NOO and your are legally in the right and invest your refund and even pay it back, however, they still get you with having to repay the loan. So blinded by the sun of free and easy money and offensive tactics against the CRA that you all didn’t bother to watch your back where the real enemy was who just raided your bank account and crept off into the night… then come the vultures… the scam arttists preying on the shell shocked victims. It’s gonna be long night mates.

  325. I’ll tell yot something else… If you are communicating with anyone other than your lawyer or someone you know personally to be trustworthy, you are taking a big chance. Even people posting here could be phishing for your personal details just to take futher advantage of your disoriented state.

    If someone asks you how much you are in for or how much you owe… ignore them as it’s none of their business.

    If someone asks for your email to communicate or provide assistance… ignore them.

    If someone you don’t know asks for money… ignore them.

    Then read this:

    They maybe you’ll want to buy some drugs, maybe take some of them, cut your losses and kiss your assets goodbye.

  326. COIP, PanAggregate et al. breached the loan conditions when they failed to supply pharmaceuticals to anyone in the first place (as per CRA review). They took the prepaid loan money and ran with it. Ultimately, even if CRA had not questioned the inflated value of the pharmaceuticals, they would have rejected the tax claims by investors since COIP and PanAggregate never really bought or disbursed any meds. I suggest speaking to a Lawyer and exploring the class action option at this point.

  327. Good comments about the CRA being the only legit entity involved. my opinion is legit companies dont need to share PO boxes with several other companies in the British Virgin Islands like the Justice Trading Company. They also dont need to book space out of Toronto by the day like RLG. Google the word Con Artist. Greed got is into this but i dont think giving these Cons more money is the answer. Good luck to everyone, my intention is to pay the CRA back with interest and penalties and hope the promoters and presenters get there’s one day!!!

  328. I stand corrected RLGs office is listed as being in Edmonton??? Does anyone know if they are open for business?

  329. Don’t forget to repay your loan and CRA!!
    You signed with RLG, Mission Life etc… They will collect!

  330. The loans with PanAggregate et al were pharmaceuticals which they were to purchase and forward to the charity……. CRA has indicated that there is no evidence that there were ever any pharmaceuticals purchased by them to forward to charity hence, there was no loan. We are due our prepaid interest, plus interest at the rate they have set out in their claims. Talk to a lawyer before giving anyone a penny. As I said, this will probably go to class action as have other tax shelters which were set up.

  331. Thanks for the info Tom. Any thoughts on going after the promoters and associated businesses through small claims? I’m not well versed in the legal side of things as it pertains to cases of fraud like this. COIP, PanAggregate, Orion and now, Integrated Receivables, may have liability insurance, personal or business assets that can be targeted? Just throwing out suggestions at this point. Obviously, SunRx and other entities that don’t actually exist have nothing to go after but PanAggregate and it’s owner may, especially if Integrated Receivables cons anyone into writing them a cheque.

  332. I have contacted some legal teams in Ontario regarding Class-actions. If any of you have any promotional documents provided from RLG or MissionLife promoting the validity of these programs, then please email me at :

    (Feel free to create a fake email account if you are not comfortable using your real email address).

    By the way I have also received a letter from RLG to pay back the interest on my loan and how it would settle any loan requirements. They and whoever is associated with them will not get one penny from me. This is a pure cash-grab from their end. Everything I have read up on their operations is fraudulent and based on some legal sources they would not hold up in a Canadian court.

    Here is a link on an article about the founder of the Orion foundation, who then setup COIP, then RLG and now MissionLife Financial. Please take the time to read it.

  333. People…….These are real loans you have with RLG/MLF/COIP/PGI. Take them to a lawyer to review if you wish. If your lawyer says that they are not real loans have him/her put that in writing for you. I will bet they won’t.

    Please be careful what you say on here because you are giving miss information. Read your loan documents and they state for example with COIP/PAN you owe back pharma. For RLG/MLF you owe back the principle amount in cash or return the coupon with the repurchase of pharmaceuticals.

    Please look at this link in regard to what’s happening.

    If you don’t settle your loan at arm’s length, the loan will be deemed limited recourse and you will have to pay back the CRA your tax credits plus interest. If you don’t plan on purchasing your own pharma to settle your loans legally, compliantly and at arm’s length you should pay the CRA back today!!! If you use RLG/MLF/COIP/PGI option for settling your loans you will be doing so not at arm’s length because the president of Intergreted Receivables Management is owned by the son of one of the main princials of the tax shelter company. It’s easy to research just do a corporate search. They are throwing you under the wheels of the CRA bus.

    BTW it has been stated on here that the donations didn’t happen…..This is totally in accurate. Please be careful what you say on here. If you make a comment that sways a donor/client on here in a direction that will ultimately destroys their postion with the CRA, you will be doing unjust!!!!!! Be careful please!!!!!

    I am sure this is going to stir a lot of conversation. I look forward to this.

    If you are not a lawyer, accountant, professional financial advisor please don’t say things without knowing what you are talking about. You have to know the tax shelter industry and understand what’s going on.

    Please do not go with RLG/MLF/COIP/PGI option because they just want your money. There is a very reliable, legal, legit and arm’s length solution to this mess if you are interested in know more. Look at the link for evidence.

    Thank you!!!

  334. I received a letter from SunRx say my prepaid interest was used up in 2010 and I need to pay interest about $2k and $1k for pharmaceutical to settle my debt.
    I came cross this website and found we do experience the same. I did regret for what I did in 2006 to participate this complicated COIP program. The agreement we initially assigned was the application for the loan with out pre-paid interest. We never got confirmation from any of the financial instute, like PanAggregate, syaing we had the load, the term and obligation….. Is this still considered as a valid contract??? Plus, CRA has stated there is no document has proved COIP, PanAggregate did as what they claimed. Based on this, we shouldn’t owe anyone money. Instead we should get back our pre-paid interest……
    We should consider class-action. I haven’t deal with lawyer before. It seems they are very expensive…. From now on, I will follow this post…. pls let me know if there is some actions we should get this settled and cleared….. I am a normal guy, and want to live on a normal life…… Life is short ….. Thanks.

  335. sorry for some typo-error:
    1. the application for the loan with our pre-paid
    2. saying we had the loan
    BTW, I am not good at investing…… I paid back CRA. Since I filed NOO in 2009, I haven’t heard any word from CRA or COIP or FASTtrack………..

  336. Here is a response from an Income Tax Consultant on the recent letters of RLG regarding the settlement of the loan:

  337. I apologize for the spamming, but here is another important link regarding the RLG letters and some more information on their founders:

  338. How about if I buy the pharmicuticles . Will this help with the CRA

  339. Will the CRA allow my original payment made?

  340. Ama, I don’t see how that would help your situation with the CRA. I wouldn’t buy any pharmaceuticals or pay back any loan agreement as the loan agreement is not a credible one. Worry about paying back what is owed to the CRA only. Whatever you do, do not give one more penny or even communicate with RLG

    By the way, please discard my two previous links. I must apologize, I read more articles on the Profit Giving Canada website and they’re suggest using “Justice Trading Limited” to pay back the pharmaceuticals and settle your loan. It appears Profit Giving Canada is a brand new group and their site is designed to get people to use Justice Trading Limited instead of going through RLG to pay back there loan.

    I repeat, do not be fooled by any group approaching you to pay back the pharmaceuticals. They are sharks jumping on peoples fears to have this settled. You will not be more advanced by paying back any fake pharmaceutical group. Focus on what you owe to the CRA right now.

  341. Will the CRA take into consideration the checks I wrote ?

  342. Not sure what checks you are referencing Ama, but the CRA primary interested is in getting back the money or reductions you received from them related to your participation in the tax shelters + interest.

  343. The prepaid interest checks to COIP

  344. Stax, how do you know that the prommisary note I signed is not real. CRA is claiming it is a sham for donative reasons, but how do we know it is not a loan contractually? I deffinately owe something (thats what 2 different lawyers have told me)…they also said that these prommisary notes could be resold…
    Please explain to me why they are NOT real loans?


  345. David Whidden is the main member if Profitable Giving Canada! He was found guilty !’how are you suppose to trust this company!!

  346. David Whidden is the founder and partner of Profit Giving Canada.

    take a look at his…

    TRUST NOONE!!! Expecially the people who sold you COIP/MissionLife/RLG in the first place!!

    Focus on what you owe to the CRA thats it!!

    • Hello All,

      I don’t normally follow these types of discussions but a friend told me my name was here, so this will be a first and last comment. Yes, I had a problem with the OSC 5 years ago, I made a big mistake that has cost me both in reputation and financially. But for those that take the time to look at the settlement with the OSC, you will see that there was never any allegation of fraud or anything remotely criminal. I made the unknowing , but unforgivable mistake of not making sure I and the program I was using personally was registered with the OSC. I have put that behind me now and learned a lesson.

      But my situation is irrelevant to the main topic at hand. Yes, I have been a member of Profitable Giving Canada for about 4 years now, but I am hardly alone. It is a group of people with membership growing just about every day. The members are there to band together for support and protection. I am proud to be a member and I am presently serving as an administrator and director. Our committee members include tax and legal professionals, a former CRA auditor, and other business professionals. So I believe the voice of PGC is one to be listened to.

      Regarding RLG and the other related programs, I was also a senior agent for them until they turned into a debt collection agency. I believe the RLG program to be the most compliant program that has ever existed in Canada and I still believe so. But there are two things remaining to be done to ensure the tax court will agree. First, the debt must be settled. Anyone who claims it is not a real debt is feeding the CRA argument of sham loan and will end up writing them a big cheque. Secondly, the debt must be settled at arms length and according to the terms of the contract. The RLG settlement proposal is clearly not arms length and just a money grab. Settling for cents on the dollar at non-arms length is an indemnification that will vitiate the loan for tax purposes and hence the tax credit will be lost. There is only one way to settle the debt compliantly that I am aware of and that is through the Justice Pharma program. I have now settled my 2008 RLG debt compliantly and have all of the documentation needed to prove it.

      That is all I have to say, other than to wish everyone luck with whatever decisions you make for your particular situation.

  347. Guess who i’snt answering there phone!! Bunch of crooks!

  348. Hi Jerry,

    Im not saying the loan isn’t real. What im saying is that when push comes to shove, these loans would not hold up in a canadian court. This offcourse is my opinion, but my opinion is based on off the record discussions I had with one of the lawyers that worked on one of the three class actions lawsuits. I also spoke with one of the auditors in the CRA who also expressed the same comments. Offcourse this is all verbal and nothing on paper, but both these people are very aware of the promissionary notes and how the tax shelters operate.

    My main message is to focus on paying back what you owe to the CRA and as others have expressed, do not trust nobody, especially what the tax shelters tell you.

  349. CRA will always say that everything is bad, they just want to collect on everything. Do you work for CRA Stax?

    How can you say the loan is real and at the same time say it is not?

    Sorry, but I think you are trying to give me some very poor advice…

  350. What 3 class action Lawsuits?? There has not yet been a class action on any of these programs.

  351. What 3 class action Lawsuits? As far as I knew none of these programs were currently involved in a class action.

    As well “off the record” statements are useless to myself, and others. Basically off the record is not even their opinion….thats jus BS that can serve the needs of CRA and greedy Lawyers.

    Has anyone actually settled their loan or loans with any of these tax shelter companies?

  352. I would be very suspicious of any one on here trying to scare innocent people into paying these loans or else. Pay a few hundred dollars, talk to a lawyer to find out if these statements regarding the loans are correct. Alot of cons out there that wont think twice about lying cheating or doing what ever it takes to extort money from innocent people. One thing they dont do is have hard earned money of their own so they have to try and steal ours. Consult a Lawyer and do what you think is right based on valid information. Everyone on here has an agenda including myself, but I earn my money.

  353. Can we call RCMP to investigate this? Why can’t CRA do sth to clear up the cloud?

  354. Here is the a brief summary points on the one classaction that settled:


    6. What happens to the promissory notes I signed in favour of Rochester Financial Limited?

    The court granted a declaration that all loan agreements and promissory notes signed by Class Members in favour of Rochester Financial Limited in connection with the Gift Program are unenforceable by Rochester, its successors or assigns.

    This means that you will not be required to make any further payment to Rochester or anyone else under the loan agreement or promissory notes.

    The court order granted was not intended to affect the rights of class members in relation to appeals to the Tax Court of Canada with respect to assessment or reassessment by Canada Revenue Agency. We are not aware of any present ongoing tax appeal before the Tax Court of Canada.

    1. How was my entitlement calculated?

    Your share of the Settlement Fund was calculated on a pro-rata basis. The total available net Settlement Fund amount was divided into the total aggregate donation amounts paid into the Banyan Tree Gift Program by all Class Members. This pro-rata calculation results in a payment of approximately $566.00 per $10,000.00 of donation amount.

  355. We are all on the same boat! I have no clue how to settle. SUn RX, Profitable Canada..
    To settle with profitable Canada is really expensive ($.10 on the total loan) Its really expensive.
    To settle with Sun RX is reasonable in comparison BUT not too sure its legit!

    Right now i am trying to get the CRA to meet with me so i can start paying back my tax credit. I won’t spend $1 more than i have too..

    I truely dont believe that the CRA cares how your loan is paid off! they care about the amout we paid paid inregards to the tax break!!


  356. Jerry,

    1) Banyan Tree Class Action – settled for 11 million and the judge declared that the promissionary notes are void- (

    2) ParkLane Class Action- in process (

    3) Trinity Class Action -in process (

    All three class actions are against similiar operated tax shelters and all processed in Ontario by Judge Strathy . From what i know, I dont believe there are any active class actions against RLG and MLF as it takes many years before the class actions are launched.

    I do not work for the CRA Jerry, if i suggest paying them back is because thats money owning to the government and if I have to take information provided by the CRA , lawyers and legal documents vs information provided by RLG, right now RLG doesn’t seem to credible. I suggest you read the court proceedings in those 3 class actions web site, a lot of interesting info.

    im also curious to know if anyone has actually paid their promissionary loans back?

    Feel free to email directly Jerry . Id prefer we work togeather then against eachother to find a solution.

  357. I think the Banyan Tree settlement involved a negotiation where in the defence agreed to have the prommissary notes tossed?

    The others don’t involve promissary notes.. and look to be in the courts for a very long time.

    There must be a way to settle the loan compliantly and prove to CRA that they are full recourse as apposed to limited recourse…

    I will wait to see if someone has settled their loan as of yet…give it a bit more time…

  358. Stax, thanks for the info and doing that background research. I paid back CRA in full as it is clear this is all a house of cards. I will not be paying PanAggregate/SunRX or anyone else as they did not purchase ANY pharmaceuticals in 06 when I contributed. They do claim to have purchased a possible token amount of meds in 07 but certainly nowhere near what would have been needed to cover the 07 COIP receipts and claims. CRA questions whether or not they ever had any meds whatsoever. I’m ready to go after our prepaid interest anytime as they didn’t uphold their end of the agreements although I expect any funds that these operators have access to is already offshore somewhere. If anyone has spoken to a lawyer about moving against these people let me know at Thanks in advance.

    • Class Action Lawsuit, I am all in, Who purchased the program in Alberta? We need to go after the Marketers of the Program as well as Mission Life. The only reason the we participated in this program is that through slick salesmanship, misrepresentation and dishonest deceit we were convinced to commit. So we need to use the tools that are available to us and that is through Criminal Proceedings and Civil Suits. One other thing is that we all have to take action and not be embarrassed by our stupidity. Take the time to put together a Criminal Package and place the complaint with your Municipal Police Force or RCMP detachment. Concerning a civil suit, collectively we have a large voice so lets get it going…Tom

  359. They just threaten you with collections to “collect” on the loan. To me that means they dont have a strong legal case to take people to court over it, even when some participants pay a lot into it!

  360. Profitable Giving Canada and Justice Trading are in bed together and Have same founders.

    The issue with making an arms length purchase is all fine and dandy in principle, but the weak link is Ackuran who is also in bed with RLG so that arms length portion is shattered rendering the entire cycle a sham in the CRA’s point of view.

    The cat is out of the bag. All of these “companies” that are here to “help” you all have their domains registered in the past 6 months. Everything has been scripted by a master mind by the name of Shy Kurtz who is conveniently not in Canada at the moment.

    The Lawyer that “Justice” is using has also been involved in another charity.

    Everything has been “orchestrated” from the start to milk us out of more and more money.

    Call CRA. Tell them you F-ed up. Ask to settle whats owing. Chances are very good they will give you credit for the original amount you donated so you are technically only out the interest (3.5%) which is the price paid for what sounded to good to be true. Helping People fight aids and get a nice income tax return.

  361. Thanks for the comments Steve.

    I just want to add that it is important to go after these promoters not just financially but also criminally.

    If we want this to stop, we need to put pressure on the authorities to bring them to court.
    I have opened a file and provided any information I have with the CRA Informants Leeds Program (1-866-809-6841).

    I know a lot of people here, like me are hoping out of no where a class action will arise or all this will be resolved out of the blue. The truth is that this needs to be a collective effort. We all need to do our part.

    Regarding a class action, if anyone has any promotional documents that were provided to them, that vouches for the validity of this program, then please let me know. This can go a long way in possibly setting up a class-action.

    Finally, like many have mentioned, don’t trust nobody, be skeptical, people have their own agendas and any advice here including mine, doesn’t replace the advice of a lawyer….but I think more good then bad
    can happen by people sharing what they have learnt and gone through.

    As you can tell, there are many going through this.

    • Stax, My complaint is also into the Leads Center, I put together a detailed statement and all of the data I could get and couriered the package to the address.
      Also I have make a Criminal Complaint to the RCMP in Alberta where I was sold the Mission Life Financial — Trinity Global Support Foundation — Fraud.
      I am just finishing my package for the Ottawa Police Service to get the investigation going out in Ontario.

      So again, I encourage all of you to put in the time and get the ball rolling on this monumental Fraud. I assure you and I will use the terms used in the Law Enforcement and the Political world. It is in the PUBLIC INTEREST……

  362. STAX
    I have eveysingle piece of promotional document they had. email me at

  363. I am so glad to have found this site. Tried several times today to get on and wouldn’t load.
    We received a letter from PanAggregate today telling us to settle our loan to SUNRx via Integrated Receivables Management Inc. The letter gave us 2 options. Phoned the IRMA and got in a yelling match with the guy.
    We, too, paid off CRA in full with interest earlier on. We have no idea what to do now with this letter. Please don’t judge us harshly when I tell you we completely didn’t understand the contract we had signed and never realized we ever owed any loan!!!! The whole presentation was SO confusing.
    Needless to say the letter came as a shock. And disappointment. And anger.
    Help Someone!!!! Please advise!!!

    • Fay,

      Your not alone . Email me at and ill let you know what info I gathered so far,

    • Hi,
      Malheuresement je ne parle pas anglais je prend donc une chance de communiquer avec vous. J’ai recu la même lettre que vous demandant de payer pour les intérets et j’ai également tout remboursé au gouvernement. Bref même scénario que vous et je ne sais quoi faire , avons-nous l’obligation de payer ??
      J’aimerai que vous me fassiez savoir ce que vous avez fait de votre coté.

  364. Hello, I am in the same predicament as all of you and wanted to discuss the situation to find a solution. I donated to the COIP (Fight Aids Save Taxes) program in 2006 and 2007, and now I am wondering what to do about the CRA re-assessment and the loan re-payment.

    I was quite surprised when I received the document requesting re-payment of the loan as I was under the impression that the pre-paid interest would be used to buy pharmaceuticals to pay off the loan. This was the information that had been given to donors, and it was in COIP’s promotional material as well, therefore I don’t believe that they are entitled to collect more money from us now.

    Personally I am much more concerned about the money owed to CRA as every year I get a notice on my tax return stating the amount owed and the interest keeps adding up. I’ve filed a Notice of Objection (NOO) as recommended by COIP and was hoping for a negotiated settlement with CRA, but now I’m not sure how everything will play out because things are not unfolding as they should have. I guess my concerns here are:

    1. Is there still a possibility of a negotiated settlement with CRA? I would be more than happy to pay back the refund that I received if the interest was waived. I would still be realizing a loss on the pre-paid interest for the loan to COIP.

    2. Is there a possibility of a class action against the promoters of the tax shelter so that we can re-coup our prepaid interest or even any portion of it? CRA claims that there were never any pharmaceuticals delivered, in which case the loan itself would be invalid and we would be entitled to get our pre-paid amount back with interest.

    I assume that most of you would have the same concerns. In hindsight, I would think that none of us would have even gotten involved in the first place had we known how things would unfold. I believe that most of us had good intentions, which was to make a larger donation to charity than we would normally be able to and also save some money on taxes, and we all believed that the tax shelter complied with the tax laws. This brings me to my third point:

    3. Assuming the COIP program does in fact comply with the tax laws, does it make any difference whether we pay back the loan as requested by Integrated Receivables to SunRx? For example, say we made a donation to charity on our Visa card and claimed the tax credit, but we never paid our Visa bill – that doesn’t invalidate the donation itself does it? We did in fact still make the donation, and if we don’t pay our Visa bill then Visa will take us to a collections agency to get their money back, but it should have no impact on the tax credit. So in this scenario, whether we pay back the loan to Integrated Receivables or not, will it have any effect on the validity of the donation and to a greater extent, will it invalidate the whole tax shelter? I don’t believe so. I also don’t understand how COIP/CRA could say that some people’s donations are valid and other people’s donations are not, based on whether or not they pay Integrated Receivables. So this results in two scenarios, either:

    (a) COIP did in fact deliver the pharmaceuticals and we owe the money to Integrated Receivables to pay off the loan, in which case we should have our CRA interest waived and should receive some sort of negotiated settlement with CRA.


    (b) COIP did not deliver the pharmaceuticals and we owe money to CRA, however, since we are not the ones at fault for not delivering the pharmaceuticals (we claimed the tax credit assuming that COIP had delivered), we are owed back our pre-paid interest plus money we paid to CRA, all with interest from the promoters themselves, in which case I assume we would have to pursue a class action.

    In any case, it can’t be both (a) and (b), either the pharmaceuticals were delivered or they were not. The problem is that CRA says that they were not delivered and COIP says that they were, so as a donor, how can we know who to pay back? It is certainly not fair for us to be expected to pay back BOTH CRA and the COIP loan.

    I’m sorry for the long-winded e-mail, but I assume these are the questions on most peoples’ minds. I do regret having participated in this tax shelter, and I consider it a learning experience. However, what’s important now is to find a solution and a way out of this. I believe most of us are good people and did not have any bad intentions. In any case, I think it would be wise to communicate with other people in the same situation such as yourselves to determine the best way forward.

    If anyone has any ideas or any information regarding a class action or how to deal with the CRA, please let me know, I would very much appreciate it. We could also possibly set up a discussion group so that we can all contribute our ideas and communicate easier, or simply “reply all” to this e-mail. If there is already a discussion in progress regarding this topic, I would be grateful if you could provide me with the details on how I could join the discussion. Thank you in advance!

  365. Both myself and my spouse participated in COIP for 3 years, 2007, 2008, 2009, We have paid back all of the money owed back to CRA and filed all the NOO and the forms to have the interest wavied, etc….
    Our Questions are about this new letter saying we owe SunRX for interest due.
    1) Can they take this to collections if we don’t pay – we do not want our credit rating wrecked.
    2) Why is all 3 years of interst due all at the same time????
    3) Is this actually a part of the agreements we signed? Can they legally ask for this, even with all that has happened?
    We just want the nightmare to end, and stop being involved with this money grab. We would love to get our money back (wishing that can happen), it has been 5+ yrs and it is like a bad relationship you just can’t get out of. No matter what you do to get ahead, it pulls you back in.
    Any advice
    Thanks April

  366. As stated in the 2008 CRA audit “…the CRA has not been provided with sufficient evidence to substantiate that the promoter purchased the pharmaceutical units, that the charity ever received the pharmaceutical units OR THAT THE PHARMACEUTICAL UNITS EVEN EXIST.”
    Pretty clear to me what CRA’s position is and what my position is regarding anything that I owe to these crooked promoters. Clearly they owe us our prepaid interest. There is no loan. Just waiting for someone ambitious to start the ball rolling on class action or other against these con men, but in the mean time, just for fun, I will figure out what my prepaid loan plus interest looks like and draft up an invoice for PanAggregate lol.

  367. FYI Thank you for the info! I believe the original contract was never honoured by COIP. We were never made to think even for a moment we could expect a bill in the mail and owe more money. Also, the charity they used, Orion Foundation, had its charitable status revoked by CRA. Also, Revenue Canada has stated in an approximate 30 page letter to me in regards to my 2009 donation that when investigated, they could never prove pharmaceuticals were purchased or distributed. These promoters made a pretty penny off of us and now they are coming for more!!??!!?? SCAM. SHAM. And who is SUNRx??? Never mentioned in our contract either!

  368. I am trying to negotiate with CRA! I’m fed up!
    I’m not paying anything to anyone other than the CRA!

    I asked numerous times for proof from COIP that the pharmaciticles I purchased were actualy purchased and delivered! They say it will be proven to the CRA!

    Who is SunRX?? Why is IMR collecting? He sends me an email and signed it with his first name???
    Never did they do a credit check! I was never suppose to pay this loan with cash! the promotion pamphlets I have clearly states its paid by the prepaid!

    Lesson learnt! Trust no one!

  369. I would be interested in doing a story on this whole mess. If anyone is interested in speaking with me, you can contact me through this page:

  370. I think it is time for us to all start going on the offensive with COIP/PanAggregate/Integrated Receivables…
    The battle with CRA is a no win situation unfortunately. The writing is on the wall. If you have invested your refund smartly you may do ok on that end. The problem now is that these crooks are now coming after people for more money. With these shady transfers of supposed indebtedness from one company to another, they are trying to legitimize non-loans. At the risk of over simplifying things, our agreements were that we would pre-pay interest on purchased pharma in exchange for a charitable donation receipt. As CRA has pointed out, COIP cannot document that they purchased any pharma for the 06 donations and possibly a token amount for 07. These transactions even if they did occur, do not qualify as charitable donations hence, no legitimate charitable donation receipt can be issued. Of course this whole thing is flawed on so many other levels that it screams fraud on the operators part. The Orion stuff is well documented but the more recent stuff with SunRx shows these guys know no limits. As I have stated, SunRx doesn’t exist, it can’t even be a bank account anywhere hence Integrated Receivables entering the picture. SunRx as a “pharmaceutical supplier” lol, would need to be registered with Health Canada. Obviously and for anyone who checks, they aren’t so, it is illegal for them to possess, distribute, import or export pharmaceuticals in Canada. Again, no surprise that they don’t exist. Their claim however is another example of where these guys are coming from.
    Time to talk to some lawyers, maybe the ones involved in the last class action stuff and shut these guys down. They do owe us our prepaid interest plus interest however I expect that with all these sketchy transfers of title, the principals are distancing themselves and their assetts from the reach of the courts. That being said, I think it is time to start moving against them. If anyone has any suggestions I’d love to hear them. Maybe we should alert the Toronto Star and get them involved again. They have got a pretty good investigative team it appears. It will prevent those who are out there on their own from being played by these guys and taken for more money.

    • Class Action Lawsuit, I am all in, Who purchased the program in Alberta? We need to go after the Marketers of the Program as well as Mission Life. The only reason the we participated in this program is that through slick salesmanship, misrepresentation and dishonest deceit we were convinced to commit. So we need to use the tools that are available to us and that is through Criminal Proceedings and Civil Suits. One other thing is that we all have to take action and not be embarrassed by our stupidity. Take the time to put together a Criminal Package and place the complaint with your Municipal Police Force or RCMP detachment. Concerning a civil suit, collectively we have a large voice so lets get it going…Tom

  371. Please don’t mix up the two! CRA is challengeing the tax receipt you gave! Not the loan!

  372. Please don’t mix up the two! CRA is challengeing the tax receipt you gave! Not the loan!
    I feel like its a scam! The loan was to be paid back from the prepaid!

  373. You may want to file a report with the RCMP Commercial Crime Division. The RCMP may or may not tell you that COIP, Pan Aggregate, RLG and SUNRx are being investigated by them as we speak..
    Profitable Giving Canada recommends using Justice Trading to settle the debt.
    They have just recently settled the first case through their lawyer which you can have access to.
    Good Luck to us all.

  374. I agree not to pay any one our hard earn money again. Please let me know if there is a class action on this. I entered COIP in 2006 and received CRA letter. Why did CRA only send out letters to us and not doing anything? So many innocent people still enroll in this type of program everyday…….

  375. I certainly am not paying these guys one more cent. They are in breach of the contract we signed with COIP. There was never to be any more monies requested or loans called in according to the letter of agreement. I can not advise anyone but I would send IRM a letter of dispute. If you send them any more cash it’s like blood to a shark. If anyone starts a class action, let us know!

  376. The contract with COIP is being breached. We were not supposed to pay a thin dime more. We were never told they would or could call in the loan. I will not pay another cent. Send IRM a letter of dispute and if someone starts a class action suit let us know!

  377. You can contact Charles Rotenberg ( tax lawyer ) 613-233-2675 he is looking after an effective way to clear this up. It will certainly cost some money but it is a way to settle the loans and conform to CRA.
    He will give you some additional contact info. COIP, Pan Aggregate MLF etc will not get any of this money. Mr Rotenberg will also go after any unused interest on our loans.
    We can do it.

  378. Matt, look at my previous post.

  379. Unfortunately the loans are legal and must be settled. For those of you in COIP the only way to pay the loan is with pharmaceuticals which can and is being done. Dont send them money to cover the COIP loan because the contract states pharmaceuticals. Make sure you abide by the contract repayment guidlelines so CRA will accept the loan as valid and settled. Also don’t send money to SUNRx as they are an offshore organization who refuses to let CRA audit them. They have something to hide.

  380. Doris Law Firm is representing Profit Giving Canada and Justice Trading!!!

    People be aware! Not get fooled!

  381. I am in the process of touching base with the three law firms that were and still are involved with the three class actions. I will see if they have interest in picking this up based on the promotional documents I have for COIP from some of you. For class actions , the law firms only get paid if there is a settlement in which they can pay their fees. If anyone has promotional documentation for RLG and MissionLife then please contact me at:

    I want to becareful about what information I give out here, as I know for a fact that former and current members of these tax shelters read and post in these comments. I know of at least three of them that have jumped ship from COIP/RLG/MissionLife and now are involved with Profits Giving Canada a.k.a Justice Limited and trying to con people again for more money. Please becaureful about anyone promoting Integrated, SunRX, Justice Limited (who’s corporate address is in the Virgin Islands!) and any law firms that vouch for them!

    I also want to repeat again, that we must go after those people not just financially but criminally. Any information you have, especially any correspondence with them, should be shared with the CRA. I have contacted the CRA Informant Leeds Program @1-866-809-6841. The more pressure we can put on the CRA , the better our chances of putting these people where they belong, behind bars!

    • Stax, I have done the same. Report and package to the LEEDS Center, Fraud Complaint to the RCMP in Alberta and just finishing my package for the Ottawa Police Service in Ottawa.

      I encourage all to put in the time, do a detailed statement and submit the complaints for Fraud over $5000. This Crime Family has to be stopped.

  382. The loans are not legal and the contract was breached basically from the outset through Orion et al and their non-charitable use of funds, failure to procure pharmaceuticals etc. We owe no pharmaceuticals or money. I believe once a good neutral law firm reviews this situation, that will be their assessment as well. As for CRA, take a step back and look at this whole scheme. Ultimately, it wont hold up in any tax court and their will be nobody representing our cause anyways. If you believe that COIP is mounting a major legal challenge to CRA’s audit then you are mistaken. Any monies earmarked for “legal defense” are in the pockets of the original promoters and probably being moved offshore as we speak along with any other traceable assets that they might have. I invested naively into this whole thing without really digging into it too much but in hind sight, it was an attempt on all our parts to save an unrealistic amount of tax. Lesson learned. I’m not worried about conforming to CRA to try and get my tax break, it will never ever happen. Don’t be lured into purchasing pharmaceuticals with the naive belief that if you do so and hold up your end of the deal that CRA is going to say “great” and allow your tax claim. It wont happen. In the end they will allow you to claim only an amount that was actually spent on pharmaceuticals for charitable purposes. This will not include any of the monies which we prepaid or that COIP claimed to have purchased. So, if you go out and actually pay $20,000 for pharmaceuticals, they will allow your claim on your 2013 return and you can get a rebate of maybe $9,000. You will be out of pocket $11,000 and will have done a good deed. It will have no impact on the scam COIP transactions. The whole buy low, sell high COIP philosophy has clearly been disallowed by CRA and that was the whole basis of the tax shelter. Again, the CRA issue is a done deal from my perspective, pay them back and move on. It’s the crooks from COIP/Orion/SunRx/IRM that we need to go after.

  383. Hmmm, so tell me how he is going to clear this mess up. I hope it doesn’t invlove participating in a “Better Program” and if it does will Doris Law endorse the program. I guess if it doesn’t work I am certain the Class Action Lawyers would be curious of the amount of Liability insurance Doris Law carries. That is of course if they will formally endorse the program.

  384. Why would we want to settle loans and conform to CRA? Steve is absolutely right. I have contacted CRA and this whole scheme is being disallowed. There are so many issues, so worrying about legitimizing your loan for CRA purposes is pointless. I have contacted Richard Pon of Fast Track out of St Albert. He has shared what he has done in response to his loan letter. I would highly recommend calling him and requesting he email you a copy of the letter of dispute. He was very compliant and has been fielding calls on this continually. Ph number is 1-(780) 418-3427 . I believe the toll free number is 1-877-470-4918

  385. I have been reading all these posts carefully, because I too am caught up in this mess. I am still very much torn on what to do and how to proceed, but one thing I do know for sure is that we have all been scammed. Many of us had no intention of defrauding the system, as it was all explained as a tax shelter just like any other, i.e. RRSP contributions are also a tax shelter of sorts. All of this seemed legal and unfortunately, we are all caught up in a huge storm. What does settle my nerves a bit, is to know that there are so many of us in the same situation. I would hate to be alone on this.

    Here are a few things that I can share, that can hopefully add to the discussion and perhaps help us all make informed decisions on how to proceed.

    1) In a Toronto Start article written by Kevin Donovan in April of 2009, he wrote, “COIP says the $1400 pays the interest on a long-term $7000 loan used to buy lifesaving medication. The loan is from an offshore company registered in Costa Rica that will, the Star found, never ask for its money back.” I would like to know how this was discovered, because in effect, it would mean that choosing to not settle with IRM will not result in us being handed over to a collection agency.

    2) When the emails/letters initially came out from PanAggregrate/COIP that we can now settle this debt, I called the 1855-529-3667 number right away to get some answers. I was told someone would call me back. When they called back, my caller ID said ‘TAX CONQUEST’ and with an area code of 587. I looked this up, and found that it’s an area code for Alberta. Yet on the email/letter, Integrated Receivables Management says to be located in Scarborough. When I asked them about the number, they said they had no idea why it came up as ‘Tax Conquest’. And when I looked up Tax Conquest online and visited their website, there is no contact information, not much about the company, just some links to CRA articles. This is a message on the site:

    Due to legislative changes made in Budget 2013, the team at Tax Conquest has elected to suspend sales. We appreciate having had your business and will still be available to assist you on a customer service level.

    Please refer to the links below for detailed information on the relevant budgetary changes that have necessitated this decision. While we at Tax Conquest are not tax experts, we feel strongly that these changes lower the value proposition of participation in any affected program.

    The Tax Conquest Team

    … sounds to me like they too may have been involved in some sort of sale.

  386. To everyone that participated in RLG/MLF/COIP/PGI……….

    There are two seperate issues here. One, these are real loans/promisory notes. The tax shelter companies can and will come after you for these debts. If you talk to a lawyer and your lawyer says not to do anything, don’t pay back your loans “get your lawyer to put that in writing for you”!!!! There is a legal opinion from Charles Rotenberg stating that these are real loans and they need to be serviced. “A writen legal opinion”!!

    What needs to be done if you decide to settle your loans you must do this legally, compliantly and at arm’s length transaction. The tax shelter companies are not providing you with a legal arm’s length transaction. If you go with them “pay the CRA back today”!! I attended a seminar that Justice Trading put on and they explained everything in regard to what needs to be done. They aren’t pushing us to by pills from them, they are explaining the “facts” to what happen and what you need to do if you want any chance with the CRA. There are hundreds of donors settling their loans with this arm’s length transaction Justice Trading and by doing so they are setting a class of people proving that these are loans. Once again there is a legal opinion on this matter.

    In regard to the CRA, they don’t want you to settle your loans! They want to have your claim to be deamed limited recourse which is what will happen if you don’t service you loans. You will have to pay everything back to the CRA plus interest and maybe penalties. If you go with the tax shelter options of settling your loans it will be deamed limited recourse because it isn’t an arm’s length transaction. All transactions of debt will be audited by the CRA and they will find out.

    If you want your tax postion protected and have a huge fighting chance with the CRA pay back your loans according to the laws and rules of the income tax act. Must be done at arm’s length.

    If you don’t want to do anything pay back the CRA today so that the interest clock stops ticking on you. Plus start saving money to pay back your loans in full or at least so that you can fight the tax shelter company in court when they come after you.

    If you want to learn more about what is happen on the Justice side of these transactions you should contact them. They are very straight forward and provide a lot of information which will I believe push you in the right direction. The seminar I attended was very educational and I am pleased that I attended. I am settling my loans through Justice because they have a law firm in place to handle everything from being to end of settlement. I encourage you to do your research before you continue to write things on this blog that will put other people into default on their loans and make the CRA attack even harder to fight.

    There is a lot of information that is being spread on here that is “not” correct. Don’t be misinformed because it is very dangerous!!

  387. Rue, good one, talked with Richard, eye opener.

  388. I found some original documents that state “PFC loan is only repayable in MU’s” … medicinal units.

    And again later on the same document “PFC is paid back for initial loan with replacement MU’s”

    … so why would we agree to pay them any more interest, in cash?
    Similarly, I never got a letter asking me to pay for an additional 3 years of interest like some of the other posts imply. I contributed in 2006 and 2007. If that interest expired four years and repayment was due after 4 years, why am I only being contacted now, in 2013???? Any other debt you may have, as soon as something is due, you know about it. And not years later. I think the list of ‘why not to pay’ is growing longer and longer for me.

  389. People, please don’t drink the Kool Aid. Don’t accept from anyone that these loans are legitimate, least alone a group who self-professes to be your only way out ie. Profitable Giving Canada. Do you think they are doing this to help people or make a buck? Do you think they run “seminars” in the hope that you wont purchase pharmaceuticals from them or buy into their legal support etc. Ultimately, if you read the info on the Profitable Giving website it basically confirms that the original loans were in fact a sham. What they are trying to do is somehow put the genie back in the bottle which is impossible. As CRA has pointed out, COIP/Orion et al never took legal possession of medicine units to legitimize their supposed loans to us in the first place. Little or no medication units ever existed according to CRA and their tax experts, legal experts, tax policy experts etc. They also pointed out that even if the meds had existed, this was inherently not a charitable donation hence no charitable giving hence no legitimate charitable receipt could be issued. It’s like paying off your mastercard with photocopied money, it may look real but it isn’t. So again, we need to look for a leader to spearhead a legitimate review of our position and then take these crooks to court if it appears there are any assets that we can go after. Again, for those of you who still think there will be any success with CRA, take a step back and look at what you are expecting the govenment of Canada through CRA to do, give you free money in unlimited ammounts at no risk to you just because some crooks called it a charity! Really, does it make any sense? Quit grasping at straws, pay off CRA and lets deal with the real crooks.

  390. +1
    I’m also interested in joining a collective action suit.
    Participated in COIP donations three consecutive years (2006-2008), on the premises laid out by the program (pretty much summarized in this long forum).
    and on the internet:

    I’m outraged at the new requests for money from PFC / SunRX / IRM “to settle” the initial loans… nowhere in the initial presentation was implied that we will have to pay additional money.

    • And by the way – here is an email address i can be reached at: gicah123 at outlook dot com
      I’m also interested in a honest settling of PFC/SunRX/IRM interest claims.

      Almost everyone on this discussion list is saying lately to not pay them anything anymore.
      But I fell for their first request in Sep-Oct 2012, and paid ~7-800 interest.
      After creating a precedent I’m not sure if I can change my mind and reject their request for more money (or pharmaceuticals, and interest) – received in April this year. another ~6k

      And I still have to pay back CRA’s tax credits – whenever I’ll have the money… another headache. But I want to escape COIP’s mess first.

  391. I found this on the web…I wonder where the journalist is now?

  392. Anna…Kevin Donovan is still with the Toronto Star.

  393. You do not need to pay the additional interest. You can send them a dispute letter. They can not contact you after that. If they send it to collections you can say COIP was negligent in fulfilling the agreement obligation and that is why you refuse to pay. If they go bankrupt no one in their right mind would purchase such a toxic promissary note. There are too many ifs ands buts and maybes. It would quite easy to prove their negligence. There is all kinds of evidence available from copies of presentations that ex COIP sales people have that would prove COIP did not follow through at their end.
    The question is Does COIPs neglect jeopardize the tax credit we received?? If so, just cause to file a statement of claim for Initial donation amount plus interest plus the amounts paid to the secondary charity plus interest plus the amount CRA says you are in arrears due the tax shelter including interest and any other additional interest you paid in relation to your COIP participation. If our tax credit is not compromised by COIP failing to satisfy our loan than no need to pay anyone anything. We did our part. Throwing them money is throwing them a lifeline, they are a sinking ship. If our tax credit is in jeopardy we have been defrauded.

  394. The names mean nothing. I will post no more info under any name. Good Luck to you all. B

  395. Well Joey, joe, Billy, Dougie, John, Brent or whatever your name is it appears you are using this forum to convey propoganda. If you really do want to assist people you “John” mentioned there is all kinds of evidence from copies of presentations that would prove they didn’t follow through. I know for myself it would help me make my decision to have such evidence re: RLG. I will not go through JT and if I had such evidence I probably wouldn’t write RLG a cheque either. Here is a thought, send the evidence to Stax if you do want to help.

  396. Hey Brent it’s not offensive at all, but it really would help for you to share the evidence you talk about. As far as endorsing JT I asked if Doris Law endorses the program? To me participating in trying to buy meds at arms length at this point is like Steve said “putting the Genie back in the bottle” even if the program is valid who wants to participate in another one. Fool me once shame on you, fool me twice shame on me!!!

    • The evidence I mentioned is regarding to any verbal promises made at the COIP seminars. COIP can deny some allegations of verbal contracts not being valid but a CD rom or DVD of that person actually saying it would be a discredit to them. Those recordings are a real prize to any legal proceeding, an ex agent said there are some out there. He has access to one.

  397. Same deal with RLG there is no proof they sent the meds other than heresay. Would like to know more about that too.. Otherwise the entire loan is a sham regardless if you legally purchase the meds

  398. I participated in the COIP program in 2006 and 2007. I wished I never did.

  399. There is so much misinformation in this blog! If you don’t want to do anything with these loans to protect your tax situation……….I recommend you pay the CRA back today without delay so that the interest clock stops ticking!!! And then start saving money to fight the tax shelter company(s) when it/they come to collect.

    • Fred,
      i can guess who you work for…
      your olnly solution is to go through Profit Giving Canada (Justice Trading)! there cannot be one solution. I was told and presented that COIP Loan was paid back from the remaing prepaids! That is not what is happening, also they can not prove to me or the CRA that 100% of the meds purchased were donated!! so why will i give more people money! CRA isnt really conceren how the loan is paid back but is questioing the receept that was given on my income taxes is legit! The Origan license was remouved a year after my receipt! D

  400. Tax Lawyer said…
    He does not believe COIP, Pan Aggregate, SunRx are at arms length.
    He believes giving more money towards more interest etc is a waste of money.
    He has and is receiving plenty of calls regarding COIP, with many participants believing they have been fraudulently taken. The lawyer coudn’t say if there was fraud. He does not know that.
    The Lawyer believes 100% we will have to pay CRA back all our tax credits we received less interest.
    He suggests for now to ignore paying any more interest or any monies to the tax shelter entities. Sit back and see what develops.
    Suggests paying back CRA over time.
    He wasn’t aware of Justice Trading so he had no opinion on that course of action.
    This is one Tax Lawyer opinion. Did anyone else receive a legal consultation and get a different opinion.?

  401. Does anyone else find it fishy that PGC recommends that Justice trading is the only option for settling our loans, while simultaneously sharing board members?

    Add the fact that the same person advocating JT on here is posting under multiple names and red flags start to fly.

    Do your research folks, try and find anyone that recognises this “regulatory body”. Also ask why said “regulatory body” has no concerns with ANY other tax shelters out there. Where are the advisories on Via, GLGI, ICC?

    I mean, don’t get me wrong, I think COIP dropped the ball on closing our loans in time, and while I am not a fan of having to pay this “additional accrued interest” I really just want to put this whole thing behind me.

    From my conversations with both sides, one side is saying “you have to purchase through us” and the other side is saying “so long as you fullfill your loan agreement, either method is acceptable”. This is all quite confusing to me, but the more I look into it, the more I question Justice Trading motives.At least IRM is has an interest relief option and a written garentee it will close my loan (something the offer from JT seems to be missing conveniently).

    Take what both sides say with a grain of salt, and do what you think is best for you.

    • Becca, My only question is why are you getting pulled into this nonsense further. If you were with COIP, you have no loan to repay. I’m sure somebody out there will gladly take your money and run with it, people will give you receipts for more pharmaceuticals or debt free status notes or whatever you want it you give them cash, but my question is why? What documented loan of any type do you have? Not some fake letter sent to you by COIP or a demand notice from Pan Aggregate or Sun pharma or Integrated Receivables, none of the crap stuff, a real loan that you made? Do you actually think you owe anybody anything. If you do your homework as you’ve suggested I think you will find that, like the rest of us, you were conned. Now the same conmen are asking you to play again. Don’t get burned again. There are people starting to explore the options open to us. My fantasy would be that we could somehow get our prepaid interest back but ultimately, I believe that because these are essentially shell companies operating out of hourly rented offices or virtual offices in unknown locations, we have no recourse to get our money back. That being said, I up for at least a try with whatever group ultimately chooses to put these dogs down. As for the whole COIP structure and tax shelter scam, that is a done deal. Pay CRA back what they have asked for and avoid further penalties and interest. The whole thing was a scam. Don’t be conned into thinking there is some magical OJ Simpson dream legal team out there that’s going to challenge CRA and get some judgement in our favor. There are no lawyers, no legal challenges and no monies to pursue such even if it was viable. Most of that cash was spent on Arion’s personal expenses and hookers.

      • @Steve

        Perhaps you do not keep a copy of agreements you sign yourself into, but I do have a copy of both my 2008 and 2009 COIP applications. Do you know what the first page’s title is?

        “First Loan Application and Limited Power of Attorney”

        I do in fact have a loan Steve, and if you participated in COIP, I imagine you do as well. You say that I shouldn’t get wrapped up further, and yet all I am doing is closing out what I got wrapped into in the first place. I knew there was a loan, I knew it would have to be repaid. The only aspect I didn’t expect was allowing my 2008 to accrue additional interest, and asking me to close them both out at the same time.

        I did not walk into this arrangement naive, and I’m not overly happy about the repayment process. In the end, what angers me even more is the fact that there are people here pretending to be “helpful” with obvious secondary agendas.

      • Yes Becca, I do in fact keep copies of things I sign myself into LOL. And yours, like mine says the same thing. Only difference is that you believe yours is legit, even in the face of overwhelming evidence to the contrary. Only one group has bothered to look into it “CRA” and they gave it an overwhelming “no pharmaceuticals purchased or existed” hence, no loan. You do realize who you got yourself in bed with when you signed on with COIP don’t you? Conmen and thieves. I think that they will very gladly and happily take your money when you offer it to them and I am equally certain that they will give you another equally fraudulent “signed document” that will say anything you would like it to.
        On a side note, yes, there are lots of smooth talkers on here willing to help people like you out with your loan problem. Fortunately, I don’t have a legit loan so my only interest is in seeing these crooks in jail if possible. I won’t be sending anyone any money.

  402. Anna,
    The RCMP link that you have provided is about synergy group tax shelter

  403. As of May 2013, COIP is demanding mire money from us original patsies.
    The company claims it is for loan payments.
    The company also claims they are CURRENTLY fighting CRA in court.
    I can find no record of a court action by COIP against CRA.

  404. PGC is really working hard to get people to go through Justice Trading.. They agree that what Sun RX is not at arm’s length and they are trying to convince you to repay a loan to protect the tax receipt.
    As Becca said. If you go through PGC your loan will still be outstanding..
    I truly don’t believe if the CRA cares where it outstanding or not, its questioning the company that issued the donation receipt and how much pharmaceuticals were actually donated and at what price.
    Question is why would I try and reimburse a loan to a company that can’t prove to me the following;
    1- Proof of purchase pharmaceuticals (the tax receipt isn’t proof) and delivery. I am the client, why can’t they simply just send me proof. I’ve asked numerous times. They tell me the receipt is my proof!
    2- Why Sun RX (a company that just opened up). They will send you a letter stating that your loan is paid back but still no proof of donation and why is the :son’s company collecting”
    3- Promotional documents vs what is being done isn’t the same.
    I’m doing nothing for now other then try and negotiate something with the CRA…. I think I will have to wait till they contact me to negotiate at the same time as other donors..

    This situation sucks!!

  405. Has any one else read the “Enthusiastic Endorsement” PGC gave to Justice Pharma Program? Do you not find it odd that the letter is signed and requests Justice to contact the undersigned if they have any questions but there is no name near the illegible signature or contact info. Just find it a little odd.

  406. Bret,
    I am waitng for a class Action Suite against coip. I want to go after my prepaid interest and my loan NULed!

  407. Just to follow up on Brent’s comment, don’t be confused by the date that CRA revoked Orion Foundation charitable status. That is just the date that they finally processed years of fraud that Orion was clearly involved in. What that revocation means is that none of the Charitable receipts issued by Orion were legitimate. It doesn’t matter what year you contributed. The fact that they still had charitable status during preceding years is irrelevant. I would think that this reality will be a key factor in a Class Action as their handling of our money in clearly non-charitable ways makes their behaviour negligent and fraudulent. The non-procurement of the pharmaceuticals as well as numerous other factors should ensure a victory for any class action. My belief however, as I have stated in the past, is that these criminals have no funds that we can ultimately draw from. I am certain, given the shading actions of late with SunRx and Integrated Receivables, that all monies are safely tucked offshore and beyond the reach or untraceable by the legal system.

  408. My concern is that even if we get a class action suit going, these fraudsters have long since stashed our cash away in off shore accounts that no-one will ever access. They would have no shame in doing such a thing given how they have swindled us all so far.

  409. The same is with HEDAC for RLG. It too was revoked for fraud and lack of proof.
    Yet the Crooks at Justice are stating its very legit because tax receipts were issued :)

    The Continue B.S. that drivels out of RLG and Justice is just amazing. How they “pit” themselves against each other like each are gospel when we know they are all the same people.

  410. Any updates on what’s going on? If someone can lead a group action to get issues resolved, please let me know. Thanks.

  411. Hi guys,
    Nice to see others are doing some great investigative work out there. I’ve been busy the last couple of months so haven’t kept up on recent posts. Was going to do a bit of checking up on some of the COIP and PanAggregate crooks with a Private Investigator friend of mine but at this point it looks like the cat is pretty much out of the bag. They ripped us off, stole our money and they owe us our Pre-paid interest. I would hope that as a group we can get some feedback as to the viability of a Class Action against whomever might have some cash left. If their are any monies left in legal funds we should go after that as any legal challenge to CRA will surely fail. There is zero chance of the tax shelter ever being seen as legit so no use flogging a dead horse and wasting money. For those of you who haven’t repaid CRA yet, this would certainly help offset that debt. If we don’t go after it you can be guaranteed that the crooks at COIP, Orion, SUN RX and PanAggregate et al will be using it to fight us and keep themselves out of jail. Ultimately, they will try and use OUR MONEY to keep us from collecting OUR MONEY. If that isn’t irony, I don’t know what is lol.

  412. any recent updates on this? Thanks.

  413. Re: Your 2008 COIP Donation Program

    Attached is your June 30, 2013 Statement of Account Payable from Sun Rx. Please review this statement so that you may settle your 2008 COIP program. This very important last step completes all such loan obligations and you will not be required to pay anything further after this for the 2008 COIP program.

    You will recall from previous communications that PanAggregate has assigned your Promissory Note to Sun Rx, its pharmaceutical supplier, together with any prepaid interest. As a result of Sun Rx being in the pharmaceutical business, and the ultimate recipient of the repayment of medicine units, Sun Rx is able to offer you significant savings and eliminate any concerns related to repayment.

    Please click the link to see the 2008_sunrxletter.pdf (Not on file) and the 2008_sunrxstatement(30jun13).pdf.

    If you have already made your payment, thank you and please disregard this email.

    If you would like a hard copy mailed to you or have any questions regarding the settlement of your loan obligations please contact Integrated Receivables Management Inc. at 1-855-529-3667.

    Please rest assured that although your debt obligations have been assigned, PanAggregate will continue to provide you with ongoing support in relation to the program.


    Steve Arnold
    PanAggregate Financial Corporati


    • You don’t pay it. Plain and simple. This is a form letter that the crooks send out trolling for more cash.

      • Thank you for all the inputs. Me & my husband were also caught in this mess w/ COIP/Panaggreggate/Sunrx and wondering what to do to get out from this nightmare. I guess I have to ignore the statement of accounts for now and wait until we (all of us involved) can come up with a solid solution.

  414. I see some recommendations for law firms, and also many requests for information on possible class actions. If someone has a solid lead, that is, a commited law firm, please ask that firm’s lawyer to post a notice here so we may write to him or her and get busy with a solution.
    Thank you

  415. Thanks Tom,

    thats what i thought

  416. I was involved in the COIP tax shelter program. Recently I have received notices from IRMA asking me to settle the loan. I have decided to pay back CRA and have paid back about 75% of what I owe. I am still very uncertain about what to do regarding this other contract. Can anyone out there give me any advice. I have spoken to the rep from Justuce Trading but am worried that it is just another scam. It sounds good and I have received a copy of their contract. I’m uneasy about sending another ten thousand dollars to them. What will happen if I simply ignore the COIP loan. After all it has turned out to be a scam. I realize I will likely lose my tax credits but at this point I really don’t care. Just want this to go away. I read a few comments about a class action suit. I would be interested to learn more.

  417. I read all of these post and I get more confused. I posted back in May and the debate still continues. Do we pay or not?

    If yes , do we go through Justice Trading or pay Integrated Receivables? What is best and cost effective way since we have already overpaid on this venture….

    If No, what do we need to send to dispute this repayment of interest to Integrated Receivables? And is there a class action law suit that is in the works, what do we need to join?

    We are looking for the best option for us, at this time in our life can not afford having this go to collections by doing nothing…..

  418. I just received a call from Integrated Receivables asking for the money. I told the caller I decided to go to the court to settle this issue. As said, first, I was told the load was prepaid. The deal was done. Second, RCA denied the claim and there is no proof about the medicine was purchased…. Hopefully, I won’t get any call…. Like said, I don’t want to leave a rope on my neck….. I want to hear the authority’s rulling about this case…. and give it period…………

    • All individuals who received letters, emails for money from IRM, COIP and all these related elements should report this dubious activity to the Canadian Anti-Fraud Centre at 1-888-495-8501 or This is a division of the RCMP. You may need to wait on the phone for awhile as they are dealing with alot of fraud. All individuals who donated have received letters from the CRA that the donation scheme is fraudulent. You may want to email Kevin Donovan (the reporter at the Toronto Star who broke this scam) at Apparently some individuals have been receiving harassing phone calls from IRM. This should be reported to the authorities.

      • Fraud Victim — Mission Life Financial – Trinity Global Support Foundation 2009-2010 and 2011.
        I cannot emphasize enough that you take the time to put together a concise statement and package and register a complaint to the Canadian Anti Fraud Center. It is your duty as a victim and in the public interest that you commit the time to register your complaint. As a large group the authorities have to listen. I sent my complaint by registered mail to make sure it arrived.

    • Hi Joe. I’m not a lawyer or anything, but as a debtor, if this really is a debt, you have rights when it comes to collections. I would file a harrassment complaint in the jurisdiction that you’re in if you feel that you’ve been mistreated. I also believe that in pretty much all provinces in Canada, a collection agency needs to have a license. If IRM falls into this category, ask them to produce their license and then validate with the authorities in Ontario.

  419. Hmm, what should we do??? RLG who apparently purchased MUs and donated to HEDAC who was revoked as a charity by the CRA for obvious reasons. because it was a SHAM!!! No Donations, No Tax Credit!!! Pre paid interest was to pay off the loan, never happened. However RLG still thinks we owe them money. Seems to me they breached their contract. Wait if we send them more money they will forgive the loan. Wait, if we send Justice even more money they will see if they can pay the Loan by buying MUs. they say it is all legit because Doris Law will hold the funds. By the way, one of the directors of PGC is also the registered owner of Justice Trading, (google justice trading and you will come up with a number company who recently changed it to “justice Trading” 7801742 . one of PGCs directors is listed as owning the # company.

    Greed got us into this mess but I personally have difficulty imagining that paying more money into it will help get us out of it. My money is going to CRA

  420. I myself are also caught up in this nonsense. I spoke to a litigation and tax lawyer and he too also tells me not to pay this group or anyone affiliated with them any more money calling it a scam.

    I’ve also seen a lot said on this forum that many are waiting for a class action suit to commence. The best thing everyone can do is to move forward with the process themselves. The more people that come out about this the faster something can be done. Scarfone Hawkins would be a good place to start. Their website says that they are looking into the possibility of pursuing other leveraged donation programs because they’re attempting to collect on what are likely fictitious loans. The link is here:

  421. Thanks Kurt. I read the program promoting flyer and the contract which I assigned. It’s clearly said the second loaner (PFC) is paid with the medical units. …. I don’t see why we are still asked for the money….. I am sending the dispute letter. I am really disturbed whenever I received the call. Meanwhile, I am filing the fraut complaim to RCMP…….. Let’s do our best to get these rats off……. Cheers……Joe

  422. Thanks Kurt. I read the program promoting flyer and the contract which I assigned again. It’s clearly said the second loaner (PFC) is paid with the medical units. …. I don’t see why we are still asked for the money….. I am sending the dispute letter. I am really disturbed whenever I received the call. Meanwhile, I am filing the fraut complaim to RCMP…….. Let’s do our best to get these rats off……. Cheers……Joe

  423. Just another thought: Currently, we are busted by both CRA and the loaner. We could be wrong for one, but not both. As CRA has denied the program, then the whole thing is scam….

  424. Does anyone has idea how to deal with interest request from PFC (PanAggregate Financial Cor) from COIP programme? Anyone consulted lawyer yet to file case?

    • Hi James. First off, I’d like to say that I’m not a lawyer, so please don’t take my word as gospel, however, being in a similar boat, these are the options I would consider.

      I would consult the promoter whom got you into this. There is a possibility they may be able to help. You could also consult your own attorney.

      If a class action is the way you want to go, I would consult the Scarfone Hawkins lawfirm. Here you can read that they are considering class actions against leveraged donation programs that are asking for repayment:

      Also, if you feel you’re the victim or fraud, like many others here, filing a report might not be a back idea. With the CRA’s reassessment letter, the closing of various charities, news articles, promotional materials, obvious complaints by others; it’s certainly something to look at.

  425. Dear fellow donors, after extensive research and contemplation, I decide to do the following to deal with the current situation:
    – Send seize and desist to IRM, Panaggreate or whoever ask me to settle the loan. Tell them to go to the court to pursue the loan and stop any contact with me. If enough of us doing this, they won’t have enough resource to take any legal action against every single one of us.
    – if they continue to harass, report to authority.
    – Do not send any more money to try to pay off/settle the COIP loan as there is no loan from the beginning and the whole scheme is based on fraud.
    – Pay back CRA to stop interest ticking. I know it is har.
    – Don’t waive any right to appeal any CRA decision when I try to pay down amount owed to CRA
    – After the reassessment is done and if rejected (very likely), appeal for the cash amount you put into the charity as regardless what COIP did, we did forked some cash and by definition, became “poorer” after the donation.
    – email Kevin Donovan (the reporter at the Toronto Star who broke this scam) at
    – contact
    – report to RCMP fraud department 1-888-495-8501 or

    I hope all of us this COIP participants will act together to minimize the damage. Good luck everyone as we need it. Really wish I had never met the COIP promoter :-(

    I am collecting emails to create a mailing list so it is easier for us to coordinate our actions. If you wish, you can send your email to I will try to form a donor group in this matter. Don’t be too frustrated. I just hope we learn our lesson and move on. It is not worth to kill ourselves for. Good luck everybody and let’s stick together and go through this together.


    • There is so much “misinformation” being posted on this forum that I feel compelled to tell the whole story about what is happening with COIP, RLG, MLF, PGI, CRA and PGC. I hope at least the acronyms are understood here, including RPGA (Registered Profitable Gifting Arrangement).

      I have been intimately involved with Profitable Giving for almost 10 years now and have been fortunate enough to be educated by some of the most knowledgeable legal and professional experts in the industry. And a lot of what I learned came the hard way: through experience. So if it’s worth anything to some of you willing to keep an open mind, here is a summary of the situation:

      •The tax credits originally achieved were valid and should not be repaid to CRA, but only if you do the right thing now.
      •The donation loans that formed part of the RPGA contracts are real and should be treated as such. They all need to be settled in accordance with both contract law and tax law.
      •The CRA and the national press do not make the final decision on your tax position. It is the Tax Court of Canada that will decide.
      •There is a real SCAM being perpetrated by the above tax shelters, however, it is not the original donation or the interest collection activities. It is the way they propose to settle your debt.
      •There is a real legal class action being formulated, but for reasons different than indicated here and with an organization that has the legal and financial resources to defend its members.

      If you want to read the rational and see some proof to support these statements, please read the Whole Story at

      One last item: I am also serving a term as a Director of Profitable Giving Canada and I can assure you that none of the PGC Directors have any interest or control over Justice Trading Ltd. This was falsely claimed by Tom Gee on this forum a few days ago. The Canadian Justice Trading affiliate does serve as a volunteer on one of the PGC committees, that’s it!

  426. Haven’t been on here in awhile but with some of the recent spam being sent out by those who are trying to make a buck off of you ie. PGC, I need to weigh in here. These people will certainly provide you with misinformation in the hope that you will “do the right thing now” lol. Really!!! Please!!!

    First off, none of the tax credits accrued as a function of investing in the COIP scam are legit. NO WAY, NO HOW. I don’t know about any of the other scams, but COIP is pure FRAUD. End of story. Grossly overvalued pharmaceuticals that were never purchased being only part of the scam that was perpetrated. To believe that this transaction was even remotely close to being legitimate wreaks of profound ignorance. Hookers and Escort services do not a charitable donation make.
    So, to avoid the interest charges that will be coming, along with the penalties, you need to pay back CRA NOW!!!

    Flowing naturally from the above, the contracts that were signed are void, null, fraudulent, take your pick. We were duped out of our “prepaid interest” which was ultimately used to run the escort/hookers/bar franchises and line the pockets of the scammers that most of you know from the information provided on this forum. You can be certain that this prepaid interest which was not used to purchase pharmaceuticals will also not be used to challenge CRA or defend your interests or repay you, it will be used to defend the crooks involved when they are all ultimately taken to court. THERE ARE NO LOANS!!!

    These matters will ultimately be settled in criminal court once fraud charges are hopefully made against these criminals and thieves. It is unlikely that the COIP objections will be heard in tax court as it is highly unlikely that the crooks will be there to present themselves. For their part, it was over as soon as they received our prepaid interest. Mission accomplished. We now have some of the same con-men calling upon us for more money through Integrated Recievables but that will likely serve to finance their own personal defense funds. These people are bright enough to know that the original charitable deal is done. That ship sailed long ago and they will not be wasting any more money on trying to convince CRA or a tax court that it is legit.

    There is a huge scam which has been perpetrated upon us and it starts with the original donations and specifically involves the collections activities that are going on currently. It also includes the new scammers who are attempting to suggest that there is a legitimate loan that you have to settle and that they are going to help you out. “Just give us money”. Two sides of the same crooked scheme. DO NOT PAY ANY INTEREST AND DON’T BE CONNED INTO PURCHASING PHARMACEUTICALS FROM ANYONE. YOU HAVE NO LOAN OR DEBT TO SETTLE.

    A class action against these crooks needs to be initiated so that these crooks can be stripped of any and all resources and properties they hold which were financed through the proceeds of crime namely the entire COIP program.

    One last item: I am not affiliated with Profitable Giving or any other operator, agency, scammer or consulting firm attempting to separate you from your hard earned money. That’s it!

    • Steve…you are making uneducated, dilusional comments that are only helping to confuse and in turn affect people negatively.

      I myself will honor my contract and settle my loan, in an arms-length fashion (don’t forget you were suppose to do so from the first day you signed)

      The philanthropy happened, you also took a loan, pay your debts and continue the CRA fight.

      People on this blog suffer from severe cases of selective memory lol

      • I’m pretty sure Steve works for CRA. They often follow forums like this one and post comments. Steve’s emotional rant urging people to repay the CRA and sue everyone else is exactly what they would like people to do.

        It doesn’t really matter to me personally what people here decide to do. I have explained the story with logic and facts and in great detail. I use my real name and anyone can contact me. I suggest everyone take some time to think their situation through carefully before deciding. My current and only passion is to protect those members of PGC who have placed their trust in us. I am confident we will prevail.

  427. Jerry,
    I know some people consider hiring a hooker to be philanthropy. Good on ya. Zero philanthropy took place but for these crooks to continue, they need marks like yourself. Keep on drinking that cool-aid lol. There’s one born every day :)

  428. David,
    Your hidden agenda’s belie your true intent which is to try and separate people from their cash with your new version of the same old scheme. If you or Jerry (are you both trying to sell us pharmaceuticals LOL) can honestly look any of us donors in the face and suggest that COIP was legit, in the face of all the evidence, then you are both delusional. My only concern is for all the honest people on here who may be duped by either of you two who continue to perpetrate this myth that COIP was legit. PLEASE, enlighten us, explain where this was even remotely legit LOL.
    Did get a chuckle out of the CRA line though LOL. You two keep on trying to con people. My guess is that you may both be working for Integrated Receivables to be trying to instill fear in these good people in an attempt to rip them off yet again.
    Keep on checking in though, I get a kick out of the thinly veiled con you are running.

    • Hey Steve,
      You obviously didn’t read the article I posted to the link to yesterday. Your evidence is the Toronto Star articles and the CRA protocol. I have evidence to the contrary. Maybe you should check a few things out. I have only one agenda, and it’s certainly not getting anything from you!

      • David & Jerry, get real. you are the one’s with an agenda, and that agenda is to convince people that they need to pay back these fraudulent loans . And let me guess, the only way to pay them back is through Justice Limited Trading through PGC? What a joke!

        People, what Steve wrote is 100% spot on. You have been scammed once, do not get scammed again. If anybody contacts you to collect these loans or promotes paying back these loans through fraudulent third parties, please report them to the RCMP Anti-Fraud Division.

        Enough is enough!

  429. David, I’ve read your link to the sales pitch. You still continue to ignore the obvious fraud of the original non-loan. The loan was null and void from the beginning. You continue to encourage people to shovel more money into purchasing pharmaceuticals with some faint hope that there is safety in numbers. The link you gave to people reads like one of the original brochures from COIP. You are a salesman, I’ll give you that lol. CRA doesn’t care what you think of them or what your opinion is or that COIP was given a charitable status when they set up their con. They are basing their conclusions on the clear fraud that COIP perpetrated by not purchasing the pharmaceuticals in the first place, submitting forged documents and failing to keep records of inventory of transactions. That and the fact that the proceeds that they collected were clearly used for non-charitable purposes invalidated COIP as a charity from the beginning and concurrently, made the original loans and contracts null and void fraudulent transactions. Forget about the grossly overvalued numbers that were attached to the pharmaceuticals. So, in summary, there are no loans to be settled. There is no chance that fraudulent loans can be used to claim a charitable donation so the CRA appeals will fail. The only question for donors is do you throw more good money after bad. My answer is a resounding NO. To each their own though :)

  430. OMFG!!!

    This blog is completely out to lunch. Most of you do not have a freaking clue what you are talking about! For the ones who state these are not loans, I would like to see a legal opinion stating so!!! If you are such a genius about the contract law, loans, tax shelter industry, the CRA and accounting, you should step forward and offer your services to represent us all in court to fight the tax shelter companies and the CRA. If you aren’t 1000 percent knowledgeable on law, facts and tax law you should stop making such ridiculous statements that are going to ultimately effect individuals on here who are trying to make a decision on what to do.

    Steve, did you participate in the tax shelters?!!! Or are you on here to cause problems? If you participated in the tax shelters, what you are doing? Did you pay the CRA back, did you pay integrate management? Oh you probably paid the CRA back….well good luck with the tax shelter company coming after you for the loans (promissory notes) you signed. The last time I looked up contract law and promissory notes…..they are very legal.

    I recommend everyone on here to take a step back and re-evaluate your tax shelter position. Your biggest question is….”do you want to protect your tax credits”!! If not, call the CRA up today and start making payments and minimize the interest charges. If you wish to protect your tax credits, you have to read your contract and honor it. We all signed promissory notes and they are very real. If you pay a lawyer to advice you on your contract, get whatever they say in writing. If your lawyer says you owe nothing and the tax shelter company takes you to court for judgement, you can fall back on your lawyers professional insurance. Oh….but wait….there isn’t a lawyer that will put that in writing for you. However, I do know a law firm that will give you a legal opinion on what’s taking place and the fact that we all have loans to settle whether you pay the CRA back or not. If you are interest in knowing who this is, just ask.

    As for some of you on here who are making very false statements and claims, you are either very ignorant and uneducated about the law, tax sheltering and tax law and/or work for the CRA. Be very careful what you say because if your statements backfire, ultimately effectiing anyone who listens to you on here.

    BTW the CRA doesn’t give a sh%# about your debt. They don’t want you to do anything because it will be a very easy collection process for them. Scenario…..CRA “Hello mr./ms. tax client can you tell me if you settled your loans and how”? Tax Client “I didn’t do anything”: CRA “oh really, well thank you for letting us know. We will be in touch very soon” Tax client “what the F is this statement of account saying I owe back thousands plus interest, plus penalties” CRA “you didn’t do anything with your loans” Tax Client “but I was told on this blog that they weren’t real loans and not to pay anyone” CRA “well I guess you decided to pay us back. We are very happy you didn’t pay the loans off. Thank you very much”!! “Oh by the way you have 30 days to pay us back in full”!!

    The next step will be the tax shelter companies collecting on you. You will have to hire a lawyer to fight them. That will cost you even more money.

    So, if you really want to understand what’s going on you should probably contact someone who understands, educated, intelligent and informed about the whole process. Once again, do you want to protect your tax credits and do it legally, compliantly and be represent by a law firm. Your choice people.

    But do yourself a favour and don’t listen to most of these individuals on here.

    BTW…Dave is one of those well educate, informed, intelligent people who only wants to inform you of what you can do. Far from a sales pitch. Know what your options are and you choose.

    My opinion is to not send anymore money to the tax shelter companies solutions because they are not compliant with the law/tax law. If you want to do what we all were suppose to do from the beginning (buy pills) there is a solution.

    Good luck to you all and please protect your interest and don’t listen to most of the uneducated individuals on here.

  431. Hi Fred,
    Appears you may be in on the same scam as Dave lol. I have no doubt that Dave is the brightest guy you know. How nice of you to back up Dave though and assist us simpletons who couldn’t possibly understand these fancy talk legal matters lol. Your altruism clearly knows no bounds. All I need from you is the name of a lawyer who will guarantee in writing that these loans (promissory notes) are perfectly legal and that they are willing to financially reimburse me for any and all out of pocket expenses incurred if 1) The notes are found to be fraudulent, compromised, non-binding in a court of law and/or 2) In the event that CRA and the tax courts deny our donations due to negligence, fraud or having engaged in non-charitable activities which ultimately negate charitable status for the operator COIP.
    Obviously, no lawyer or law firm is going to put in writing that these notes are legally binding unless there is no fear of recourse against them. If you can hold them financially liable in writing then you can sign me up.
    Since that wont happen, how about Profitable Giving putting out an open letter to purchase our tax refunds for the price of our prepaid interest? According to Dave, whose letter suggested that he was near wetting himself over how great an opportunity these arrangements are, we should all be giggling with anticipation at our pending success in the courts. I am 100% serious here, you can purchase my tax refund of nearly 26K for the bargain price of 12K which includes my prepaid interest and the secondary donation to Greek Orthodox Church. Even if you buy the pharmaceuticals from SUNRX (which I advise against) you will be ahead of the game anywhere from 5 to 10K. No risk according to you guys with all the fancy learn’n lol. What would we window lickers do without you geniuses handling our finances and wallets for us. This is a slam dunk. I will complete all paperwork as requested and remove myself from any further involvement in or connection to this scam and the new hustlers now working the streets here. This needs to be 100% legally binding and I will have your offer reviewed by my business lawyers. I await your positive reply. Have a great day :)

  432. I agree it looks at though the program and our donations won’t hold, but who knows. What I think is: 1) giving money to COIP (or integrated receviables…) is like burning it. 2) paying CRA may be the quickest way out of this…. (at least is seems that way, super sad face) 3) If you pay Justice Trading or WHOEVER to complete the pharma purchase, the whole thing may still be denied by CRA in which case all of the money spent is wasted.
    MY MAIN QUESTION. If I chose to do nothing – not repay the “LOAN” to COIP (or associates) or provide the pharma in any form, is it going to stay on my credit record… ie will CRA be the only remaining debt? I will be speaking to a lawyer – I’ll let you know. THanks all for your info. Matt

    • Matt did you speak to a lawyer yet ?

    • Read the disclaimer on the Justice Trading Contract…….As expected it completely exonerates PGC and Justice.
      Its all about commission commission commission

      • Recent Justice Trading Update November 12th 2014

        !COIP Down
        .PGI Wobbling
        …RLG & MLF To Go

        Passing the Test-Case with Flying Pharma
        This past spring, after persevering through more than one year of daily lawyer letters and expensive wild-goose chases, Justice Trading (“Justice”) was able to do something that no one has ever done before: to settle the principal loan underlying the COIP/PFC (now SunRx) and PGI tax shelter debts. In order to do this, Justice manufactured, analysed, and audited, “Identical Pharmaceuticals” and air shipped them, on the Purchasers’ behalves, to the Designated Recipients (SunRx and PGI)—both at the same address in the United Kingdom (“UK”). And it was not easy. In fact, it turns out that the process was intended to be virtually impossible.

        Chasing the Collectors: To the UK?
        On behalf of our test-case participants, we overcame dozens of complicated logistical obstacles and regulatory riddles that no donor knew about and were not in their contract. For example, we successfully delivered restricted goods into bond in the UK, which were never permitted otherwise entry into and which cannot remain in the UK. This little UK “requirement” was never mentioned in any contract or document belonging to any of the 1500+ Participants that have joined us so far, and it is unlikely that many would have ever purchased their tax shelter in the first place had they have known this would be demanded of them after the fact.

        From Surprise to Disguise
        This surprise request was made unanimously by all the related tax shelter programs. But this should not come as a surprise to you, since they have now morphed into licensed collection agencies, whose only way of making more money is by delaying or inhibiting everyone’s ability to settle their outstanding debts, or by tricking or forcing the debtors (you) to pay more money. For example, when Justice appeared on the scene to help people settle their debt compliantly and rescue them from ongoing interest payment demands, the Promoters (now Collectors) swiftly opened up other non-arm’s length and related companies, in order to “compete” with Justice. They offer suspicious, non-compliant, and unverifiable ways of settling debt. Specifically, Integrated Receivables Management Inc. (“IRMI”), is secretly owned by James Landesberg, the son of Zeev Landesberg (one of the principals of the COIP, RLG, MLF and PGI Programs), and is under the group’s full control. For a variety of legal reasons, this means that that their “settlement solution” is actually against tax law, and, if all debtors were to participate in it, it would surely cost them upwards of one billion dollars as a result.

        Interesting Interest Interests
        Official documents of acceptance (i.e. the COIP-SunRx updated Statement of Account showing the principal debt paid-in-full, and the interest they claim is owing) were followed by confirmation by their various legal counsel to proceed with sending the entirety of Justice pharmaceuticals. Although COIP and PGI (the first and the last tax shelter programs promoted chronologically) are essentially variations of the same programs, run by the same people, and which carry substantively similar pharmaceutical settlement terms in their respective contracts, we knew that MLF had the most to lose (on paper). Why? Because MLF would have to refund millions of dollars of prepaid interest (“PPI”) if the pharma was delivered within four years of signing—and not refunding PPI would be considered more than a bad debt—it would be a breach of fiduciary duty—a criminal offense. But this did not dissuade them. Their counsel proceeded to confirm with Justice counsel that they (MLF and RLG too) would accept the terms of delivery, which had been established through the various test cases with COIP, RLG, and PGI, after all these months, and requested we send the entirety of our participants’ pharma. So we immediately arranged for our pharma to leave the warehouse for export audit, and that’s when they changed their minds.

        Chasing the Collectors (Part II): To South Africa?
        In mid-flight, the Collectors decided to renege on their binding commitment to the terms of the established shipping process. The controlling minds of the four tax shelter programs—not publicly but through their various teams of lawyers—are demanding that Justice participants ship all pills to the same freight forwarder at the same destination, but this time in South Africa, which represents a completely new unchartered process. Furthermore, they have taken the position that unless their debtors (you) comply with these new demands (through Justice), they will simply refuse to accept anything shipped to them in the UK regardless of their legal obligations and the months of delay caused especially to establish the terms of the ongoing shipments. Not only is this new demand and ultimatum not applying to IRMI settlements, it was never made public, and was never told to you—the donors. It seems the Collectors speak to no one anymore—except Justice’s lawyers that is.

        This latest tactic is not only a way of evading their obligation to take the settlement pharmaceuticals. It also serves a double purpose: to launch the latest round of their Billion Dollar Collection Campaign, aimed at thousands of unprotected donors, pressuring them to settle their debts using costly and blatantly non-compliant, and unverifiable settlement methods, created by the masters of the tax shelter boiler-room. It appears that many will be driven into bankruptcy either from the Collectors or the CRA, unless they take specific steps now.

        Here is the specific delivery status per Program:

        1. COIP/PFC (SunRx)
        COIP/SunRx immediately accepted thousands of jars of AIDS medicine, eliminating $7.8M of debt for 249 contracts/donors, with more requested and more en route!

        2. PGI
        PGI has now also given instructions to their freight forwarder, Southern Cross Freight and Logistics, to accept the entirety of donors’ pharmaceuticals that are in the possession of Justice’s shipping agent in South Africa. Although PGI received all documentation from Justice months ago pertaining to the specific pills being shipped on behalf of specific donors, PGI waited until just last week to inform our counsel that they would now like to retain an “independent auditing firm” to review the documentation prior to accepting the pills, without any explanation what there is to review. Nonetheless, further delays were incurred by PGI, until Southern Cross contacted Justice’s shipping agent just days ago informing them they are now prepared to accept the pills. Our counsel has written to inquire with their counsel if this is in fact accurate, and if so, Justice will be reporting on the confirmation of this delivery within 48 hours.

        3. RLG and MLF
        RLG and MLF are substantially the same programs, except that MLF, being promoted more recently, potentially owes back millions of dollars of prepaid interest (PPI) to donors like you who succeed to settle their debts before their initial PPI payment fully accrues, which is one of the unsung benefits and effects of Justice’s deliveries. It goes without saying that MLF has a misaligned interest to delay acceptance in any way possible, as the interest clock continues to tick, especially if they have no money to pay back to the donors to whom they owe unaccrued PPI, which seems to be the case. Because of the similarities between RLG and MLF, it makes sense that whatever MLF does, RLG will do as well, and this is why we always receive identical word-for-word letters from Agkuran and Logipharm (the respective vendors of the MLF and RLG programs).

        3.1 RLG and MLF Tactic: Reading between Invisible Lines
        Here is an example of a recent prejudicial tactic that MLF (and therefore RLG) are currently attempting to employ, which if unnoticed would have granted them indefinite and full discretion to ignore the facts and evidence of the delivery, and the terms of the contract, and to deny the actual settlement in its entirety, despite actually being in possession of the identical pharmaceuticals. It’s preposterous and yet it’s very real. Specifically, MLF and RLG informed us that our donors’ pills must all be re-analyzed, against undisclosed new and arbitrary scientific requirements and standards, determined in no specific time frame, despite the fact that Justice’s counsel supplied them with independently audited Certificates of Analysis as well as Third Party Certificates of Analysis, which were also audited by Ernst & Young and separately by KPMG. One must not forget that RLG refused and abandoned our first test shipment to the UK, based on the fact that there was no third party certification provided in addition to the Certificates of Analysis that were. Despite there being no need for this, Justice proceeded to obtain those as an expensive gesture of good faith. They could simply have done then what they are insisting on doing now: analysing the pills themselves.

        3.2 It’s the Final Countdown
        Justice lawyers, on behalf of the Participants, have issued a final ultimatum before taking further steps against MLF and RLG to mitigate the damages they are causing. We will be reporting on all developments as they unfold.

        The Final Word of Justice: EVIDENCE
        Justice understands, and has as its primary mission, the legal and commercial needs and consequences of every one of its Participants. What underpins Justice, as the name suggests, is the evidence that ensues from our actions and processes. Judges and courts look only at the facts and at the law. Justice has ensured that the contract that it has with its Participants is based on providing all the necessary goods and services as outlined in the various debt contracts with COIP, RLG, MLF, and PGI, despite their endless tactic of quibbling. Our entire business operations are around generating overwhelming and unequivocal evidence that each pill is accounted for, tracked, and analyzed by the various world leading professionals that we use in our processes. We also ensure that the movement and conditions behind every dollar of every payment is accounted for and protected, and that the terms of every order are precise, to the pill, and to the dollar, and complied with for each settlement in exactly the same way. We can establish on behalf of every Participant that every part of the settlement transaction have been perfected, and we have expert opinions to establish that it is compliant for tax purposes and debt settlement purposes. Our support goes way beyond our contractual obligations, as does our value proposition. Generating the evidence, by third party verification at every step, is extremely timely, costly, and one could even argue that it is “overkill”. But in light of the opposing forces our Participants face, and the lengths to which they will go, and in light of the fact that almost all of the managing minds behind the Justice Program are debtors of COIP, RLG, MLF, and PGI too, we have allocated all of our resources to ensuring the most reputable and comprehensive oversight of every aspect of our program, in order to give our participants comfort and value couched in real evidence, and a team to stand behind it. That’s Justice.
        Examples of evidence that each Participant receives from Justice as part their Final Evidence Package (upon delivery of their pharma to the Designated Recipient) are as follows:
        1. Ernst & Young Audit Report that outlines all systems and effects of the Justice Pharma Program™
        2. KPMG Stock and Delivery Audits conducted on a rolling basis performing independent stock audits and full delivery analysis and verifications, as evidence that specifically treats every pill produced independently.
        3. Escrow Account: Our Escrow Agent at Doris Law Office has done a flawless job for almost two years, ensuring that no dollar is released to Justice until Justice perfectly complies with all the pertinent steps of the transaction as outlined in the terms of the Purchase Agreement. All Confirmations that are issued from time to time will be re-compiled in this Final Evidence Package.
        4. Certificate/s of Analysis
        5. Third Party Certificate/s of Analysis
        6. Certificate/s of Origin
        7. Active WHO-GMP Accreditation/Credentials of Manufacturers
        8. Justice Statement of Account
        9. Justice Transfer/s of Title
        10. Justice Final Receipt
        11. Any all legal documentation provided to/by Designated Recipient
        The longer the Collectors delay and attempt to frustrate Justice Participants, the longer Justice will be there by your side. As we grow, we gain strength. And our strength is our unity—our people. We will continue to report to you, and we invite you to share your story and your evidence with us.

  433. Hey Matt, my take on this for what it’s worth and from what I’ve been able to uncover is that the whole COIP program is fraudulent, broken, a scam, what have you. I’ve gone on at length about this in previous posts. Purchasing pharma from anyone is a waste of money at this point. The program, even if it had some merit originally, was put forward and conducted in a fraudulent manner from the outset. The fact that we went in to it with good intentions and did our part is irrelevant. You can’t legitimize a fraudulent transaction after the fact. CRA doesn’t care about the loans or whether they are settled or not. It is irrelevant to them. Their focus is on the fake receipts issued years ago for pharma they never purchased. Buying pharma now or not for that matter, has no bearing on the illegitimacy of the original transaction. The initial fraud makes any further actions or expenditures pointless. Regarding Integrated Receivables, they have no claim against anyone due to the original fraud that COIP perpetrated. There are no loans as I have stated in the past. There is nothing for them to go to a collections agency with “this guy owes me drugs” lol. I pray that they try and collect in court. That will be their undoing and by exposing themselves may allow us to place liens on their corporate and personal assets. They ultimately owe us our prepaid interest plus interest. Not holding my breath till I get it though lol. As for CRA, they have us all in their sights and will collect. Nobody else has a claim against us. We do have a claim against COIP et al however. Again, don’t pay anyone anything or get conned into purchasing pharma. It is simply a way to burn money and put more money in the hands of crooks and con men.
    As a side note, I have had a few calls from Integrated Receivables. What is hilarious about this is that the people calling (always the same woman) change their name each time lol. I don’t get that part of it but it does give me a chuckle every time. Anyways, keep your money, we’ve all been burned enough or give it to a legitimate charity if you are truly feeling philanthropic. Look forward to hearing what your lawyer has to say. Good luck.

  434. Two more notices in the mail today from SunRx/IRM saying to payup with interest. I believe that’s a total of 5 now. Is anyone making any forward motion on this as to what to do or who to contact? There hasn’t been any posts on here for a while.

    • Brian:

      Everyone is probably getting these plus harassing phone calls. I talked to the RCMP some time ago and asked them about this. They told me absolutely do not pay these IMG, COIP etc. They told me the whole thing, as everyone knows, is under dispute by the CRA so this is not a business as usual situation. Contact the Canadian Anti-Fraud Centre – phone and email in other entries above.

      • Thanks Rick,
        I haven’t received any harassing phone calls yet just the bills from SunRx/IRM and have already settled with CRA but my wife is getting concered about the possibility of collections ruining credit rating. I will contact the anti fraud centre and go from there. Just want this whole COIP scam to be OVER!

  435. Good advice Rick. Thanks for the info.

  436. I think you will all find that this tax lawyer’s website, and no doubt this Toronto lawyer (Natalie Worsfold – 1-866-813-4410), are a good resource… A lot of good explanations that are easy to understand. There are a number of good links she provides and also, although not easy to see, there is a link that she has provided to the very relevant Maréchaux court case, if you click on the name Maréchaux in italics on the following web page that deals with charitable donations and tax matters:

    • Another good website I found in this regard will be of interest to those of you who may not have received the CRA’s 12-page letter explaining why it decided not to accept COIP donations for 2006. It comes from the CRA office in Kitchener, Ontario and was sent to a taxpayer in September 2008… This letter is posted on the following website right now:… but I don’t know for how long, so if it is no longer there when you read my note, please let me know as I have copied it into a file.

  437. How can the letters for interest demands and what not still be sent out. If they are scamming then how come the source of where the notices originate from do not get shut down ?

    • Hi John,

      If you look at Rick’s comments last month, on August 19, and this month, September 14, you’ll see that he recommends contacting Canada’s Anti-Fraud Centre in this regard. He provides the contact info and other details and their advice to him not to pay COIP or any offshoots. Your question is so good. It would be interesting to see the Anti-Fraud office’s response to you…

  438. I got fooled by these crooks as well I donated to mission life in 2010, 2011, and Pharma gifts in 2012 and foolishly again, early in 2013 before I learned of CRA holding refunds. I’m wondering if anybody has any updates or any news I have just received two letters from IRMA saying I owe MLF more money for interest on my 2010 2011 donations and I will receive a paid in full certificate seems like an obvious cash grab, if we don’t pay will they be able to collect? They never held up there side of the agreement by buying the medical units with the remaining per paid interest in year 3, but in my review of the contracts I couldn’t find anything in there saying they had to do that so all we have is there word.

  439. Have these guys actually sent anybody to collections yet?

    • Consider this??? Mission Life Financial and Trinity Global Support Foundation purchased their own enforcement arm in the Loan Collection Fraud. The name of this firm Integrated Receivables Management Inc. It is my opinion that they had to purchase this collection firm because a legitimate firm would not participate in criminal and unscrupulous actions against so called debtors. Their collective actions only serve to mask their fraudulent collection activities.

  440. We signed these loans under the impression the prepaid interest would be used in the 3rd year to buy the equivalent medicines on the world market which obviously didn’t happen and was never going to happen isn’t this false advertising how can they possibly attempt to collect on this when they didn’t follow there own business structure

  441. As I’ve stated many times, there are no loans. You owe nothing. The original agreements were invalidated at the outset by the innumerable frauds perpetrated by COIP et al. In committing these frauds they also invalidated the whole original donation scheme. Looking back it should have been apparent that this would never pass the sniff test with CRA anyways but if it ever had a chance it was blown out by COIP’s fraudulent behaviour. We should legally be entitled to repayment of our prepaid interest but again, as I’ve surmised in past, I expect that money is long gone to some island paradise and distant relatives of the original crooks. Don’t get conned into paying Integrated Receivables or buying any pharma with some belief that that will somehow undue to original cons and frauds of COIP. You will just be wasting your money. Deal with CRA and move on.

  442. Thanks Steve, makes sense, what about the promoter that sold us the program in person can they be held liable for anything? I contacted mine as soon as I got the first email and he is telling everybody to pay IRM and then dodging my questions they where obviously on the take too.

  443. Have any of you that got letters asking for more interest early in the year actually been sent to collections? Or are these just empty threats?

  444. Rich, They are just trolling for cash and I am sure there are some people out there on their own, especially seniors, who will feel threatened by their correspondence and pay these thieves what they ask for. I really do wish there was a way to contact all those who had been conned by these people and get the word out that they aren’t alone and that these crooks will find themselves in court at some point. Again, don’t pay any of these fraudsters another cent.

  445. Has anyone been sent to collections by these people yet the representetive that sold me the proaram is emailing me telling me to pay integrated recievibles should i report this to the RCMP

  446. FOLKS,






  447. I just receive a letter from IRM informing us that they will forward our account to the collection agency by March 1, 2014 if we don’t settle the balance owing which arose from our 2007 COIP Donation.
    Does anyone of you consulted a lawyer? If yes, what are the options available to us?

    • Vevian,
      Do you have a copy of the letter you received? would you post it so the rest of us may read it?

      • One page letter states:

        Notice: Integrated RM Inc. is under contract with the creditor to discuss your overdue account.

        Please contact Integrated RM to discus this past due account.

        Blair Wright, Compliance Officer
        Integrated RM Inc.

        Other 1 page letter states:

        Please be advised that you will be in default on March 1, 2014.

        Unfortunately, unless you bring your interest current or repay your loan in full, either in cash or by return of pharmaceuticals, SunRx Ltd. will be forced to send your loan to a third party collection agency.

        Please see enclosed Statement of Account Payable for account details and settlement options.


        SunRx Ltd.

  448. Vevian,
    I have been following this thread for a while

    The fact that IRM has send such a letter is a suprise to me, I guess I will be receiving it shortly as well.

    I am not a representative from Justice Trading. But I have been in contact with them for couple of months.

    I will following up with Justice Trading and reading a lot about them and what they do and who they are. Also attended couple of their seminars.

    They predicted couple of months ago that something like that would happened. In essence IRM was suppose to collect the debt on the loans from COIP/RLG/MLF. The problem was that IRM does not have a collection agency license and basically have no right to do so in Ontario.
    Justice Trading has been telling everyone about it and to complain to appropriate bodies in Ontario and if you search on their web site you will find this in more clear statement. So according to these guys, they tried to close IRM and stop their activity.

    This letter that you just receive seems to verify that it has been archived.
    What the letter really says is: we want to collect the dent owning to us, we do not have the license to do such thing in Ontario. So we are informing you that we will be handing this collection to a proper collection agency in Ontario.

    According to Justice Trading: this is very unlikely to happened. It will be very difficult to find a collection agency that is valuing their reputation to do this job. Whether or not this is true – I do not know, I heard this about 2-3 month ago.

    If you want to start dealing with the lawyer on this, I would suggest you do the following:
    1) As you are aware, COIP/RLG/MLF has closed the access to the website to download the documentation from them. Try getting any documentation from them. What you will find is a lot of resistance and non-cooperation. Why: they do not want to settle with anyone else?
    2) Go to a Justice Trading seminar.
    It is a sales pitch – yes, it is. It is obviously not a free seminar. They will make off money from you. But try to listen to them with open mind.
    3) Meet with a representative from the Justice Trading, you will get a document that describes their terms.

    Then take that document to a lawyer to review if you can find a lawyer that will accept to review it. You will find that it will be very difficult to get a clear answer from any lawyer on this matter, specially in writing.

    There is a lot of bad talk about Justice Trading on this thread. I feel that it is not really about them but more about the anger within people that they have been screwed over.

    The fact is: CRA has denied your claim of donation credits based on the fact that loans were a sham. Read it, you have the reassessment from CRA. The only was to make those tax credit valid is to honor the loans and pay them back. Even before I found about Justice Trading, I found a lot of issue with the way IRM was trying to settle the debt so I decided not to settle. Justice Trading came along and just confirmed it.

    You basically have 4 options:
    1) Do nothing
    Issue with this – I have a feeling that CRA will simply say to you that you never repaid the loan so based on that, everything will be denied.
    2) Settle with IRM
    There is a list of issues with this approach. Search through Justice Trading website
    3) Settle with Justice Trading
    I find it also bothering. Basically right now, none of the COIP/RLG/MLF representatives are accepting the pharmaceutical back. I had a mental block originally when I heard this. I find this to be the best option so far.
    4) Go and purchase the pharmaceutical yourselves. Go luck with that. I believe it is almost impossible, in addition you will find that you will face the same situation as Justice Trading since COIP/RLG/MLF won’t accept pharmaceutical from you.