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Definition |
Type of govt tax assistance |
Registration |
Annual accounts |
Returns |
Other monitoring |
Requirements on trading activities |
Information publicly available |
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New Zealand |
The entity must have been established exclusively for charitable purposes and for the benefit of the community or an appreciably significant part of it. |
Charities exempt from income tax.
Donors able to reduce their income tax. |
None at present.
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None at present.
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None at present.
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Little on-going auditing.
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All income is exempt from income tax when applied to charitable purposes within New Zealand.
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None.
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United Kingdom |
Equivalent to NZ |
Charity exempt from income tax.
Donors able to reduce taxable income.
Gifts by individuals are made net of tax which charities can reclaim from Inland Revenue. |
Obligatory unless an exempt charity (e.g. universities, grant-maintained schools, places of worship).
Has to be approved by Charities Commission.
Decisions appealable to the courts.
Once registered, notification of changed circumstances is required. |
Provided to Commission as part of required annual report.
Prescribed format (companies have separate rules).
Required to be audited if over 100,000 pounds. |
Only those selected for audit sample are required to file return with Inland Revenue.
Previously, all registered charities were required to file annual returns. |
Auditing by Inland Revenue. Accumulation of funds leads to enquiries from Inland Revenue.
Commission can institute inquiries regarding charities either as a class or individually. |
Subject to exemptions, including direct relationship and de minimis turnover tests, trading activities of a charity are taxed but entity is able to deduct donations to parent charity. |
Register of registered charities.
Annual reports. |
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Australia |
Equivalent to NZ |
Charities exempt from income tax.
Donors able to reduce their income tax. |
From 1 July 2000, charities have required formal endorsement by Australian Tax Office (ATO). Separate endorsements for income tax exemption and donee status - different criteria apply.
Replaced self-assessment and confirmation by ATO.
Decisions appealable to the courts. |
No formal requirements. |
No formal requirements. |
ATO reviews from time to time whether an entity is continuing to meet the requirements for endorsement. |
None. |
Entities that have donee status, through Australian Business Register. |
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United States |
Broadly comparable.
Also includes 'lessening the burdens of government' such as gifts or donations to a government unit. |
Charities exempt from income tax.
Donors able to reduce their income tax. |
Tax exemption required from Inland Revenue Service (IRS) or the Tax Court, unless gross receipts do not exceed $25,000 or are a church, hospital, or educational entity.
Material changes in circumstances result in automatic loss of tax exemption. |
Have to be kept and be available for inspection by IRS.
Private foundations have more stringent requirements because of concerns of influence of founders. |
Yes, unless gross receipts less than $25,000 or a church or related entity.
Short-form return for those with gross receipts between $25,000-$100,000.
Returns filed with IRS. |
Auditing by IRS. |
Related activity test. Unrelated activities are taxed. Related are exempt.
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List of organisations to which donations are deductible.
Requests for tax exemption.
Three most recent annual returns. |
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Canada |
Equivalent to NZ |
Charities exempt from income tax.
Donors able to reduce their income tax. |
Yes, if wish to claim tax benefits.
Has to be approved by Canada Customs and Revenue Agency (CCRA). Covers both income tax exemption and donee status.
Decisions appealable to the courts.
Once registered, required to notify of changed circumstances. |
Have to be provided to CCRA by all registered charities. |
Have to be provided to CCRA by all registered charities. |
Audited by CCRA.
Disbursement quota, although can temporarily accumulate funds for large projects subject to CCRA approval. |
Yes.
Private foundations cannot engage in business activities. |
List of registered charities. Information pertaining to registration or deregistration.
Financial statements, at discretion of charity.
Annual returns (in respect of revenue, expenses, assets, liabilities, remuneration, activities and purpose). |