Statement”), at s. 9, “We usually consider substantially all to mean
90% or more” (emphasis in the original).
 Registered charities receive favourable treatment under the
ITA. In the first place, under s. 149.1(f) all income earned by
a registered charity is exempt from income tax. Second, under
s. 118.1 registered charities my issue donation tax receipts to
their individual contributors and under s. 110.1 to their corporate
contributors. In order to maintain these fiscal advantages, a charity
must remain within the definitional guidelines set out in
s. 149.1(6.2). Failure to adhere to the 10 per cent limit on
resources devoted to “political activities” can result in the
revocation of the organization’s registration as a charity: Action
by Christians for the Abolition of Torture v. Canada,  F.C.J.
No. 1768, 225 D.L.R. (4th) 99 (C.A.), at paras. 20, 59 and 68.
 Again as a matter of interpretation and enforcement, CRA
has divided “political activities” into two general types: submissions directly to government, and public advocacy. Oral and written submissions made to parliamentary committees and other
legislative bodies, or written briefs and in-person representations
made to government agencies or officials, are deemed entirely
charitable and subject to no enforcement under s. 149.1(6.2) provided that they are connected to the organization’s charitable
purpose. CRA thereby acknowledges as a matter of administration
that there is, or at least can be, a policy and advocacy component
to charitable activities: see CRA Policy Statement, at s. 7.3. In
this respect, political activities and charitable activities are not
always treated as distinct.
 By contrast, communication of similar policy messages to
the public at large, whether in written or spoken form and
regardless of the media utilized as the vehicle for this public
advocacy, is subject to the 10 per cent rule (or 90 per cent rule,
depending on how one chooses to view it) for the “substantially
all” requirement. That is, to the extent that a charity uses more
than 10 per cent of its resources on policy advocacy not communicated directly to government officials, CRA considers it in violation
of s. 149.1(6.2) and subject to revocation of its charitable registration. It also requires the 10 per cent or less of political activities to
be ancillary to the organization’s charitable activities and that they
be non-partisan in nature, pursuant to s. 149.1(6.2)(b) and (c) of the
ITA. This applies regardless of whether the subject matter of the
charity’s advocacy or policy reform efforts fit squarely within
pursuit of its charitable purpose.
 The applicant submits that CRA’s 10 per cent rule of
interpretation and enforcement for the “substantially all”
requirement in s. 149.1(6.2) of the ITA, as applied to public policy