October 17, 2014, three years from the date the Canada Not-for-profit Corporations Act (CNCA) generally came into force, is the deadline under the CNCA for federal charities and non-profits incorporated under the old Canada Corporations Act to formally “continue” under the CNCA. The requirements for the transition are described here. Corporations Canada intends to start the dissolution process immediately for charities and non-profits that have not continued by the deadline.
For an active charity, dissolution could involve disastrous GST/HST implications in addition to potentially crippling income tax implications. The charity would cease to exist as a legal person, which would generally lead to the revocation of its status as a registered charity. Consequently, supplies by the charity that were previously GST/HST exempt because of that status could become taxable.
Steps should be taken immediately by any federal charity that has not yet continued under the CNCA.