community activism is pursued by the applicant with a view to
instigating significant changes to government policy and the
legislative frameworks that implement those policies: ibid., p. 175.
 Counsel for the applicant states that in reliance on these
and other studies, it has placed its resources and efforts behind
civic engagement and public dialogue, with the ambition of bringing about legislative and policy change for the effective relief of
poverty. While this approach may be in keeping with contemporary
activism in the poverty relief field, it is out of step with s. 149.1(6.2)
of the ITA and with the CRA Policy Statement on interpretation
and enforcement of that section. The applicant therefore submits
that the CRA’s 10 per cent rule should no longer be applied. It also
states that there is no cogent distinction between non-partisan
“political activities” and charitable activities as indicated by
s. 149.1(6.2)(a) and no reason for political activities to be ancillary
or incidental to charitable activities as indicated in s. 149.1(6.2)(b)
as political activities aimed at fulfilling the organization’s
charitable purpose are charitable activities.
 On January 9, 2015, the CRA issued a report that summarized the results of a “Political Activities Audit” of the applicant
for the period April 1, 2009 to March 31, 2012. In its audit report,
the CRA concluded that virtually all of the applicant’s activities
involved political engagement in the nature of communications to
the public advocating policy changes. The CRA stated that in its
view an activity is considered “political” where it (1) “explicitly
communicates a call to political action”; (2) “explicitly communicates to the public that the law, policy, or decision of any level of
government in Canada or a foreign country should be retained . . .
opposed, or changed”; or (3) “explicitly indicates in its materials
(whether internal or external) that the intention of the activity is
to incite, or organize to put pressure on, an elected representative
or public official to retain, oppose, or change the law, policy, or
decision of any level of government”.
 What these activities have in common that characterized
them as non-partisan “political activities” is that they all involve
communications about law reform or other issues related to the
relief of poverty. Most of these activities are public forms of
expression that represent the applicant’s efforts to engage its
constituency in democratic processes to relieve poverty in the
manner recognized by the Copenhagen Declaration and the Standing
Committee report as essential to the effective relief of poverty.
 The applicant has also engaged in a substantial amount of
activities aimed at combatting the social exclusion and stigmatization that comes from living in poverty. The CRA in its Political
Activities Audit has likewise deemed these to be restricted “political