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Can a Canadian registered charity fund activities carried out by a foreign organization?

TSL Written by the Treadstone Law team· Updated August 2026

Yes. Since reforms to the Income Tax Act's charity rules, a Canadian registered charity can make a "qualifying disbursement" directly to a foreign organization that is not itself a registered charity or other qualified donee, as long as the charity carries out proper due diligence and accountability measures — confirming the funds will be used for activities that further the Canadian charity's own charitable purposes, using a written agreement, and monitoring how the money is actually spent.

This replaced an older, stricter approach that generally required the Canadian charity to maintain continuous direction and control over the foreign work, treating it almost as if the charity were carrying out the activities itself through an agent. The current approach is more flexible and focuses on accountability for the outcome rather than requiring that level of ongoing operational control.

Charities working internationally should still document their due diligence carefully — reviewing the foreign organization's capacity, setting clear terms for how funds must be used, and following up on results — since CRA can still ask a Canadian charity to show that money sent abroad was genuinely applied to charitable purposes consistent with its own registration.

Key takeaways

  • A Canadian charity can now fund foreign organizations directly as a qualifying disbursement.
  • This replaced the older requirement to maintain direction and control over foreign activities.
  • The current test focuses on due diligence and accountability rather than operational control.
  • Written agreements and follow-up monitoring remain important documentation for CRA review.
This is general information, not legal advice. It doesn’t create a lawyer–client relationship, and the rules can change. For advice on your situation, a Treadstone corporate lawyer can help.
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