Speed Skating Canada’s CRA Revocation: Lessons On Filing Deadlines And CRA Correspondence

On September 26, 2026, the Canada Revenue Agency (“CRA”) published a notice in the Canada Gazette revoking the registration of six registered Canadian amateur athletic associations (“RCAAAs”) for failing to meet the filing requirements under the Income Tax Act (the “Act”). Speed Skating Canada was one of them.

According to the Canadian Press, Speed Skating Canada’s CEO “said the organization did send its filing on time but it wasn’t received by the CRA” and that the organization “never received an overdue notice.” Speed Skating Canada has said it is “in the process of refiling.”

Press coverage described the revocation as a loss of “charitable status.” Technically, that is not quite right. Speed Skating Canada was registered as an RCAAA, not as a charity. RCAAAs are a separate category of qualified donee. They can issue official donation receipts, and the filing and revocation rules that apply to them closely track those for charities. The practical lessons, however, apply to both.

Failing to file is the most common reason for revocation. It is also the most preventable. In its Report on the Charities Program for the 2025-2026 fiscal year, the CRA reported 2,076 revocations, 1,219 of which resulted from a failure to file.

The case also raises a broader question about the CRA’s use of its compliance powers. Revocation for failure to file is discretionary, not mandatory. In our view, revoking an active national organization for a missed filing is difficult to reconcile with the public interest when the Act provides more proportionate alternatives.

Key takeaways

• File electronically and retain the confirmation. The CRA encourages online filing through My Business Account. Electronic confirmation removes uncertainty about whether the CRA received the return; proof of mailing does not establish receipt.
• Keep the CRA’s records current. The CRA sends notices of intention to revoke by registered mail. A notice sent to an outdated address or a shared mailroom may not reach the right person in time.
• Respond to a notice right away. Filing the missing return within 90 days of a notice of intention to revoke is the simplest way to avoid revocation.
• If registration is revoked, act quickly. The one-year period to re-register and avoid revocation tax may already be running.

How does a missed CRA filing lead to revocation?

Every registered charity and RCAAA must file an information return within six months after the end of each taxation year, “without notice or demand.” Charities file Form T3010; RCAAAs file Form T2052.

If the CRA has not received the return within six months after year-end, it may issue a notice of intention to revoke (Form T2051A). The organization then has 90 days from the date of the notice to file the return or object. If it does neither, the CRA publishes the notice in the Canada Gazette, and registration is revoked on publication.

Two aspects of this process can catch organizations off guard:

1. The 90-day period runs from the date the notice was mailed, not the date it was received. An organization is unlikely to obtain relief simply because the notice did not reach the appropriate person.
2. The CRA can act quickly: there have been reports of notices proposing revocation when a charity was only two months late.

Does the CRA have to revoke registration for a missed filing?

No, revocation is not automatic. If a charitable organization or RCAAA fails to file, the Minister “may” revoke its registration (subsections 149.1(2) to (4.3) and 168(1) of the Act). Non-filing therefore permits revocation but does not require it. The Minister retains discretion to consider whether revocation is appropriate in the circumstances.

The Canadian Press described Speed Skating Canada as “one of the country’s most decorated amateur sport organizations, with a combined 10 medals at the Winter Olympics earlier this year between short and long track events.” Given the organization’s active national role, it is not apparent that revocation was the most proportionate response to a missed filing.

Revoking an active national organization, only to process its re-registration months later, consumes CRA resources, disrupts donors and funders, and diverts organizational resources from programming to administration. It may also put the organization’s assets at risk: revocation tax may apply unless registration is restored within the applicable one-year period (subsections 188(1.1) and 188(2.1) of the Act). These consequences are difficult to reconcile with the public interest when the underlying issue is a missing return.

Annual returns are essential to the CRA’s oversight of registered organizations. They provide the information the CRA needs to assess ongoing compliance. But when an established organization misses a filing, the choice is not limited to revocation or no action.

The Act provides other compliance tools, including a $500 penalty for failing to file (subsection 188.1(6) of the Act). The CRA also uses education letters, telephone calls and requests for information to promote compliance. Those measures may offer a more proportionate response before the CRA revokes an active national organization. In our view, revocation for non-filing should generally be reserved for organizations that have ceased operating, repeatedly failed to comply or engaged in more serious non-compliance. 

Even if this suggested approach is too difficult to administer, surely someone at CRA should have escalated the issue and caused the Minister of Finance and National Revenue to call the Secretary of State (Sport) – had that happened, we find it hard to imagine that revocation of Speed Skating Canada would have been necessary.

What happens when the CRA revokes an organization’s registration?

The CRA identifies three principal consequences of revocation for a registered charity: it can no longer issue official donation receipts, it loses its income tax exemption, and it must transfer its remaining assets to an eligible donee or pay revocation tax.

An RCAAA’s tax exemption and qualified donee status likewise depend on registration. In practice:

• Donations. The organization can still accept gifts, but donors receive no tax credit.
• Funding from charities. A revoked organization is no longer a qualified donee. A charity that continues to fund it must treat it as a grantee and satisfy the qualifying disbursement requirements, including maintaining documentation showing that the funds were applied to charitable activities. For sport associations, this consequence may be more significant than the loss of individual donations.
• Revocation tax. A revoked charity is liable for a tax generally equal to the value of its remaining property, less debts, charitable expenditures and transfers to eligible donees during the winding-up period.

Revocation tax does not apply if the charity is re-registered within one year after its deemed year-end (the date the notice of intention to revoke was issued) and, before re-registration, has paid all other amounts owing and filed all required returns. The clock therefore starts with the notice, not publication in the Canada Gazette. By the time the revocation is published, a significant portion of the year may already have elapsed.

Technically, the revocation tax and relief provisions in section 188 of the Act refer to registered charities (subsections 188(1), 188(1.1) and 188(2.1)), although subsection 188(1.4) separately defines an “eligible donee” for RCAAAs. A revoked RCAAA should seek advice about its potential exposure promptly.

Objecting after the deadline is difficult. The Act permits an application to extend the time to object, but the organization must apply within one year after the deadline and demonstrate, among other things, that during the original 90-day period it was unable to act or had a bona fide intention to object, and that it applied as soon as circumstances permitted.

What should an organization do after the CRA revokes its registration?

For a charity revoked for failure to file within the past four years, the CRA’s guidance states that the charity may reapply and that “registration may be granted retroactively.” The charity must:

• contact the Charities Directorate to reopen its existing account, rather than create a new one;
• file a complete T3010, with financial statements, for every outstanding fiscal period, including the period in which it was revoked;
• pay a $500 late-filing penalty; and
• provide current and complete governing documents and, if incorporated, recent proof of active corporate status.

The CRA states that the application “will follow our standard review process.” Speed Skating Canada has said that it hopes “to have the matter straightened out in a week or two.” That timeline may be optimistic. Until registration is restored, the organization should not issue official donation receipts.

The CRA’s published re-registration guidance addresses charities. RCAAAs apply for registration using Form T1189 and should confirm with the CRA which process applies to them, including whether retroactive registration is available.

What should boards do to prevent revocation?

Charity and RCAAA Boards should consider the following steps:

• Assign responsibility. Confirm who is responsible for filing the annual return, how it will be filed and when it is due, and record the deadline on the board calendar.
• Require confirmation. Ask management each year for the CRA’s filing confirmation.
• Keep the CRA information current. Update mailing addresses and contact information, consider managing correspondence through the online account, and authorize more than one representative so that no filing or notice depends on a single person or mailbox.
• Check the organization’s status. Confirm on the CRA’s online list after each filing deadline.
• Escalate CRA notices immediately. Do not wait for the next board meeting.

Conclusion: CRA should exercise its revocation power proportionately

A revocation for a missed filing is usually fixable. The resulting cost in time, management attention, donor confidence and funding relationships may not be.

Organizations should file online, retain confirmation of receipt and ensure that CRA correspondence reaches the right person. The CRA, for its part, should recognize that revocation is discretionary.

In our view, it should generally be reserved for organizations that are inactive, repeatedly non-compliant or engaged in more serious misconduct—not active organizations that have missed a filing when a penalty, reminder or telephone call would likely secure compliance. If your organization has received a CRA notice, we would be pleased to assist.

On a big picture basis, the revocation of Speed Skating Canada was not required by law – CRA chose to do so. And CRA should have chosen differently. Indeed, one might argue that CRA has a legal obligation to only revoke for failure to file when the circumstances warrant.

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