Let us know what changes you think should be made to this return or if you disagree with any of these.

Some suggested changes:

1. In the "Basic Information" at the start of the form, the section on "Program areas" asks the organization to choose its "three primary areas" from a multiple choice list of program descriptors and to indicate the "percentage of time and resources devoted to each program area". The relevant choices offered are:
   • Public education, other study programs
   • Research (environmental, scientific, medical)
   • Nature, habitat conservation
   • Preservation of species, wildlife protection
   • General environmental protection, recycling services
   If the Canada Revenue Agency (CRA) wants this information, that's fine. But the public needs better information.

   Charities with more than one program should be required to list programs as they themselves describe or name them and indicate the amount or percentage of spending for each. NGOs that do work outside of Canada should separate that work under different program designations, so that the public and see how much spending is done within and outside Canada.

2. Section D2 asks for information on the five most highly compensated full-time permanent positions. It gives the following categories, which do not go high enough:
   • $1-$39,999
   • $40,000-$79,999
   • $80,000-$119,999
   • $119,999 [sic; should be $120,000] and over
   In place of this, the specific amounts (total remuneration) to the highest paid employees should be asked for, along with the respective job titles.

3. Section E5, line 4500, asks for "total tax-receipted gifts". This should be broken down into (1) gifts from private individuals, (2) gifts/grants from foundations, and (3) gifts from companies, including gifts from foundations run by corporations.

4. Section E5, line 4520 asks for "total specified gifts included in line 4510" (line 4510 is gifts from other registered charities). What does that mean? Are those gifts that are designated for a specific purpose?

5. The section on expenditures (in Section E5) has various common expenditure categories and then an "other expenditures" category. When there are other expenditures, the organization should have to specify what these are. As it is now, The Nature Conservancy of Canada reported $43,399,804 in "other expenditures" out of a total of $56,224,816 for its 2004 return. One assumes this is largely for the purchase of land and easements, but one should not have to guess at such large amounts.

6. The return should provide information on the organization's Board members in its online return viewable by the public. This should include a mini-bio of a couple of sentences for each that includes name, citizenship, location, occupation and employer. On their websites, some NGOs include such information; other supply simply a list of names.

7. Finally, CRA's website enables the public to search for charitable organizations with a specific purpose, but its list of charitable categories is amusingly antiquated. You can search for temperance associations or convents and monasteries, but there are no categories for environmental charities or nature conservation charities. The closest category, which some green NGOs use, is "preservation of sites, beauty and historical". This does not facilitate the public finding out who is doing environmental or conservation work.

   

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