Submission to the United Nations Human Rights Committee For the 114th Session of the Human Rights Committee (29 June – 24 July 2015)

Alternative Report Raising Issues Related to Articles 19, 22 and 6

Submitted by

Canada Without Poverty June 5, 2015

1. Introduction Canada Without Poverty (CWP) submits this brief to the United Nations Human Rights Committee in preparation for the review of Canada under the International Covenant on Civil and Political Rights (ICCPR) in the 114th session of the Committee.

Founded in 1972 and operating as a leading national anti-poverty organization, CWP has represented the low-income population in Canada for over 40 years. Many of CWP’s members are living in poverty and our Board of Directors is comprised of people with direct, personal experience of poverty, both past and present. CWP seeks to provide meaningful and effective representation of people living in poverty, promoting a better understanding of the lived experience of poverty in Canada and addressing problems of stigmatization and discrimination experienced by low income people.

CWP has a network comprised of over 1,000 members across the country made up of individuals living in poverty as well as organizations representing low-income individuals. With a pan-Canadian reach, CWP is often called upon by parliamentary committees, civil society, and the media to speak about poverty as it relates to various stages of the life-cycle and vulnerable demographic groups.

Under our former name, the National Anti-Poverty Organization, CWP was the first NGO to appear before the UN Committee on Economic Social and Cultural Rights in 1993. CWP continues to promote the implementation of human rights as the fundamental basis for the eradication of poverty and acts as a central resource point on poverty and human rights in Canada. The following written report outlines two of CWP’s key concerns with respect to Canada’s compliance with the ICCPR. These concerns include the right to freedom of speech and to assembly due to restrictions on charities under the Income Tax Act of Canada, as well as the right to life as protected by the Covenant in relation to poverty, homelessness and hunger in Canada. Further to this written report, CWP will present oral submissions at the formal briefing on July 6th, 2015 at the 114th session of the HRC.

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2. Articles 19 and 22: Income Tax Act of Canada and Restrictions on Charities A. Understanding Provisions of the Income Tax Act

1. We are deeply concerned about possible infringements of Articles 19 and 22 of the ICCPR as a result of provisions in the Income Tax Act of Canada (ITA). (See also Appendix with media coverage of the issues described below).

2. Section 149.1 (6.2) of the ITA says: “For the purposes of the definition "charitable organization" in subsection 149.1(1), where an organization devotes substantially all of its resources to charitable activities carried on by it and (a) it devotes part of its resources to political activities, (b) those political activities are ancillary and incidental to its charitable activities, and (c) those political activities do not include the direct or indirect support of, or opposition to, any political party or candidate for public office, the organization shall be considered to be devoting that part of its resources to charitable activities carried on by it”.1 [emphasis added]

3. Accordingly, when an individual donates to a charity they are issued a charitable tax

receipt that they may use to lower the income tax they owe (by the amount donated). This provides an incentive for individuals to donate to charitable organizations.

4. Under section 149.1 (6.2) of the ITA, in order to retain charitable status to issue such

receipts to donors, a restriction is placed on the percentage of time and resources a charitable organization can devote to “political” activities. It is capped at 10%.

5. Political activities are defined in policy guideline “CPS-022”, written by the Canada Revenue Agency, the administrative body responsible for monitoring charities’ compliance with the law. According to CPS-022 ‘political activity’ includes when an organization “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 (if the retention of the law, policy or decision is being reconsidered by a government), opposed, or changed.”2 It also includes any broad calls to action to the general public, for example, encouraging people living in poverty to contact their local or federal member of Parliament to support or oppose a policy or law.

6. The consequence for a charity of going beyond this 10% “cap” are severe and

include the loss of charitable status for an organization. The implementation of this restriction has become an increasing impediment for NGOs to properly exercise their mandates and have curtailed freedom of expression and assembly.

1 Income Tax Act (R.S.C. 1985, c. 1 (5th Supp.) 2 Canada Revenue Agency, CPS-022 Political Activities Policy Statement, Effective September 2003. Online: <http://www.cra-arc.gc.ca/chrts-gvng/chrts/plcy/cps/cps-022-eng.html>.

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7. It is CWP’s experience that Section 149.1 (6.2) of the ITA limits the ability of charities in Canada to express themselves freely and without constraint about the causes and consequences of poverty and solutions needed to eliminate poverty in Canada, among other issues. It also infringes on poor peoples’ ability to form organizations to represent and amplify their voice in the public domain.

B. Understanding the Application of the Income Tax Act on Charities in Canada

8. In 2006 and thereafter, the Federal Government began to implement a general policy of denying funding to organizations engaged in any kind of advocacy for policy or legislative change. For example, federal funding of NAPO/CWP was eliminated in 2006 and funding for the Government’s arm’s length advisory body on the relief of poverty, the National Council on Welfare, which had been formed in 1969 and recommended many changes to federal policy in order to relieve poverty, was eliminated in 2013.

9. To make up for this loss of support, NAPO/CWP like other organizations, has focused

on developing a charitable donor base, upon which it now relies to fund its activities. Currently 80% of CWP’s funding comes from charitable donations. CWP would not be able to function if it relinquished its charitable status as it relies on charitable donations to operate.

10. In the past, section 149.1(6.2) of the Income Tax Act was not the subject of rigorous

enforcement. However, in recent years Canada Revenue Agency, at the direction of the Government of Canada, has devoted significantly more time and resources to publicizing and enforcing s. 149.1(6.2) of the Income Tax Act. In March 2012, the Government of Canada injected $8 million (CDN) into political audits of charities. This amount later grew to $13.4 million (CDN) over five years.3 These audits have included organizations that have explicitly and publically expressed opposition to federal level government policy, many of which are human rights oriented organizations. Some argue that the political audits have in fact targeted such organizations.4

11. As of March 2015, 28 organizations were under political audit (this year), an additional 21 audits have been completed.5 Organizations under audit include: Amnesty International Canada, PEN Canada, United Church of Canada (Kairos), Canadian Centre for Policy Alternatives, Tides Canada Foundation, Tides Canada

3 Dean Beeby, “Canada Revenue Agency’s Political Activity Audits of Charities” CBC News (5 August 2014) online: <http://www.cbc.ca/news/politics/canada-revenue-agency-s-political-activity-audits-of-charities-1.2728023>. 4 Dean Beeby, “Canada Revenue Agency’s ‘political’ targeting of charities under scrutiny” Globe and Mail (3 August 2014) online: <http://www.theglobeandmail.com/news/politics/canada-revenue-agencys-political-targeting-of-charities-under-scrutiny/article19900854/>. See also Don McRae, CRA Audits of Charities Look Fair but Feel Foul Toronto Star (15 April 2015) online: http://www.thestar.com/opinion/commentary/2015/04/05/cra-audits-of-charities-look-fair-but-feel-foul.html 5 Dean Beeby, “Sierra Club latest environmental charity hit by Revenue Canada audits” CBC News (30 April 2015) online: <http://www.cbc.ca/news/politics/sierra-club-latest-environmental-charity-hit-by-revenue-canada-audits-1.3052770>.

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Initiatives Society, David Suzuki Foundation, Sierra Club Canada, Ecology Action Centre, Equiterre, Environmental Defense Canada Inc., Pembina Foundation, CoDevelopment Canada, and Alternatives.

12. This rigorous enforcement of s.149.1(6.2) against charitable organizations

perceived to be expressing political views that are in opposition to the current Government’s policy has created a chill on free public discussion, debate and action regarding policy issues and legislation related to the relief of poverty and other areas.

13. CWP and other charitable organizations are constantly worried about speaking out

against policies and legislation which create or exacerbate poverty. When CWP seeks to act through networks of organizations with the common purpose of the relief of poverty, it is made clear by many participating organizations that they are unable to speak out about their concerns regarding government policies and legislation for fear of coming under audit and losing their charitable status in accordance with Section 149.1 (6.2).

14. Contrary the HRC’s General Comment No. 34 (para. 25), within the charitable sector

in Canada there is widespread uncertainty about what kinds of activities might be categorized as political activities and how the time and resources allocated to such activities is to be calculated. Charitable organizations find it impossible to chart and allocate their time and resources rationally in a manner that would comply with s. 149.1(6.2).

15. Section 149.1 (6.2) is being applied in a manner that may restrict organizations like

CWP from pursuing the relief of poverty – a long recognized charitable purpose. For example, the board and members of CWP believe that the most effective means to relieve poverty at the present time is to advocate for changes to policy and legislation that cause or contribute to poverty and to adopt new legislation in this regard, a position that is consistent with what Canada has been told by a number of UN treaty monitoring bodies. However, were CWP to allocate the appropriate amount of time and resources to engage with government and the public to bring about these required changes, CWP could lose its charitable status and thus its funding base.

16. If CWP were forced to close its doors, poor people would lose an important vehicle

through which they can engage in democratic processes. Their freedom of speech and assembly would be cut-off.

17. Harriett McLachlan is a member of CWP and is the President of CWP’s board. She

has lived most of her life in poverty. She and other individual members of CWP experience political marginalization. As individuals – without a representative body like CWP - they are unable to access policy forums and cannot exert any effective

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influence on the policies and laws which keep them in poverty and deny them dignity and effective participation.

18. As a member of an organization such as CWP, however, Ms. McLachlan and others

living in poverty are able to engage in political dialogue, appear before parliamentary committees and communicate their concerns and experiences to politicians and decision-makers. Ms. McLachlan has made submissions to parliamentary committees and submitted written briefs outlining aspects of her lived experience, which are of direct relevance to public policy and legislation under consideration by the federal government.

19. People living in poverty are frequently stigmatized, treated as burdens on taxpaying

citizens, assumed to be bad parents and to lack work ethic. Their dignity, health and security issues are often ignored because decision-makers do not experience poverty themselves and rarely have the opportunity to hear from people living in poverty. Having a properly resourced organization to advocate for policy and legislative change that addresses the otherwise neglected interests and needs of poor people and to promote the dignity and equal rights of poor people is essential to combatting this stigmatization and dehumanization. CWP and other charities whose goal is to relieve poverty, is fundamental to promoting a more balanced discussion of federal policies and programmes related to the relief of poverty.

20. Democratic dialogue and policy discussions in Canada are negatively affected by the

lack of effective representation of people living in poverty. Cabinet ministers; deputy ministers, members of parliament and high level civil servants involved in developing policy and legislation regularly meet with or otherwise communicate with representatives of charities representing particular associations or interests. Such interaction is essential to informed decision making and policy and to the efficient and fair functioning of Canadian democracy.

21. Freedom of assembly for poor people who want to join together to oppose national

laws and policies contributing to poverty is also curtailed under the enforcement of section 149 (6.2) of the ITA. It would, after all, be virtually impossible for people living in poverty to fund their own associations through membership dues. They rely on organizations with charitable status for any meaningful engagement in the democratic process of developing policy and legislative responses to poverty.

22. Experts agree that the loss of free expression among organizations representing

disadvantaged groups because of their reliance on charitable donations and the more rigorous enforcement of restrictions on political activities in the Income Tax Act, has created an advocacy chill for charitable organizations.6 This has resulted an unprecedented loss of free expression on policy issues linked to poverty and

6 Gareth Kirkby, “An Uncharitable Chill: A Critical Exploration of How Changes in Federal Policy and Political Climate are Affecting Advocacy-Oriented Charities” Royal Roads University (June 2014) online: <http://garethkirkby.ca/thesis/posting-final-version/>.

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disadvantage and has curtailed freedom of association particularly for people living in poverty.

23. Voices-Voix Canada, a non-partisan coalition of Canadians and Canadian organizations

committed to defending collective and individual rights to dissent, advocacy and democratic space, has indicated that due to these restrictions on political activity, “[c]harities have reported taking greater caution in their communications, and voluntarily reducing their public profiles for fear of being targeted for an audit. This is in contrast to their usual mission of vocally engaging in public discussions and debate in order to maximize the exposure of their public policy ideas and critiques”7.

RECOMMENDATION CWP recommends that the State party review section 149.1(6.2) of the ITA with a view to ensuring that it complies with Canada’s obligations under Articles 19 and 22 of the ICCPR. 3. The Right to Life: Poverty, Homelessness and Hunger (Article 6)8

24. The interdependence of civil and political rights with economic, social and cultural rights is a well-accepted principle, commonly referenced in General Comments and other international human rights documents. There may be no clearer example of this interdependence than the relationship between extreme poverty (and its manifestations – homelessness, hunger) and the right to life.

25. Canada Without Poverty submits that the Government of Canada’s failure to take positive steps to address extreme poverty, especially homelessness, has resulted in violations of the right to life as found in Article 6 (1) of the ICCPR.

26. Poverty, homelessness and hunger continue to be problems that are disproportionate to Canada’s wealth and resources, especially in light of the fact that, unlike other developed nations, the Government of Canada boasts of its economic well being in the aftermath of the global economic crisis.9

27. In Canada, approximately 4.8 million people live in poverty according to the Low-Income Cut Off (After Tax).10 Marginalized groups such as indigenous peoples, single mothers, newcomers and people who are racialized, persons with disabilities, youth and children are most likely to experience poverty, inadequate housing, homelessness and food insecurity in Canada.

7 Voices-Voix, “Canadian Charities and the Canada Revenue Agency” (May 2015) online: <http://voices-voix.ca/en/facts/profile/canadian-charities-and-canada-revenue-agency>. 8 CWP replies on the submissions to the HRC by ESCR Net and the Social Rights Advocacy Centre et al for a deeper analysis of the concept of interdependence. 9 Government of Canada (2012), “Chapter 2: Economic Developments and Prospects,” Budget 2012. http://www.budget.gc.ca/2012/plan/chap2-eng.html. 10 Populations living in Private Households, Low Income Measure (After-Tax), Statistics Canada, 2011 National Household Survey, Statistics Canada Catalogue no. 99-014-X2011043.

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28. Food insecurity is significant in Canada with close to 900,000 households forced to turn to a food bank each month11. This marks the second highest usage rate in the history of food bank usage in Canada and is a 26% increase since 2008 during Canada’s economic recession.

29. Nunavut, an Inuit Territory in the North of Canada, has the highest number of households in Canada that are food insecure at 28.8%, which is more than double the Yukon Territory, which holds second place at 11%.12 Olivier De Schutter, the Special Rapporteur on the Right to Food, on his first trip to Canada in May 2012, observed that there is a widening inequality gap that is affecting food security across the country.

30. The United Nations has described housing and homelessness in Canada as a “national emergency”.13 An estimated 250,000 people are homeless, with another 1.5 million living in inadequate housing, and/or facing a serious financial burden which threatens their housing security.14

31. Poverty has been recognized by the World Health Organization as the single largest determinant of health affecting both mental and physical health outcomes. This manifests in a number of adverse health issues including depression, diabetes, heart disease and other chronic conditions. In Canada, one in five dollars spent on health care is attributed to ‘health inequities’.15 These conditions can lead to ill health and the contraction of otherwise preventable life threatening diseases.

32. As Dr. Hwang at St. Michael’s Hospital in Toronto has said, “homelessness affects tens of thousands of Canadians and has important health implications. Homeless people are at increased risk of dying prematurely and suffer from a wide range of health problems, including seizures, chronic obstructive pulmonary disease, musculoskeletal disorders, tuberculosis, and skin and foot problems. Homeless people also face significant barriers that impair their access to health care.”16

33. Studies have also shown that living in shelters, rooming houses, and hotels, in other words, homelessness, is associated with much higher mortality than expected on the basis of low income alone.

34. In Hamilton, Ontario, a 21-year difference was found in the life expectancy of individuals between the poorest and wealthiest residents of the city.17 In January

11 Food Banks Canada, “Hunger Count Canada, 2011” (2011), p. 2, 8, online: <http://www.foodbankscanada.ca/getmedia/dc2aa860-4c33-4929-ac36-fb5d40f0b7e7/HungerCount-2011.pdf.aspx)>. 12 Health Canada, “Household Food Insecurity In Select Provinces and the Territories in 2009-2010”, online: <http://www.hc-sc.gc.ca/fn-an/surveill/nutrition/commun/insecurit/prov_ter-eng.php>. 13 UN Committee on Economic, Social and Cultural Rights, Review of Canada 1996, 2008 and UN Special Rapporteur on Adequate Housing, Mission Report on Canada, 2009. 14 Canada Mortgage and Housing Corporation, 2010. 15 Health Council of Canada (2010), “Stepping It Up: Moving the Focus from Health Care in Canada to a Healthier Canada”, p.7. http://www.healthcouncilcanada.ca/tree/2.40-HCCpromoDec2010.pdf. 16 Stephen W. Hwang, “Homelessness and health” CMAJ (January 2001), online: <http://www.cmaj.ca/content/164/2/229.short>. 17 http://media.metroland.com/thespec.com/statistics_flash/.

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2015, two homeless persons died in Toronto, Ontario due to cold weather, poverty and lack of adequate housing.18

35. The relationship between women’s premature death and domestic violence is well documented. Many women experiencing domestic violence have few housing options, which means they are compelled back to a violent situation or are compelled into homelessness. Either way, their lives are at stake. One study in Toronto found that homeless women 18 to 44 years old are 10 times more likely to die than women of the same age group in the general population.19

36. This Committee has already recognized the connections between homelessness

and the right to life. In its concluding observations on Canada in 1999, the Committee stated that it was “concerned that homelessness has led to serious health problems and even to death”20.

37. Despite these observations by the Committee and the Committee’s

recommendation that Canada undertake positive measures to address homelessness, Canada does not have a national housing/homelessness strategy or national poverty elimination plan in compliance with international human rights law.

38. In fact, the government of Canada has rejected the connection between poverty and

homelessness and the right to life. In the ongoing court challenge Tanudjaja v. AG (Canada), Canada’s position has remained that there was no state deprivation of the right to life in the State’s actions in sustaining and contributing to conditions of homelessness. In fact, in a response to a claim based on the right to life, the government filed a Motion to Strike to prevent the application from being heard in the courts.

39. CWP respectfully submits that that by failing to take positive steps to address extreme poverty, homelessness, food insecurity Canada has presented barriers to the right to life for people living in poverty as protected in Article 6(1) of the ICCPR.

RECOMMENDATIONS

We agree with the submissions and recommendations made to the HRC for the review of Canada by the ESCR-Net Strategic Litigation Working Group in conjunction with member groups the Social Rights Advocacy Centre and the Charter Committee on Poverty Issues.

We support their suggested recommendations and paraphrase them, in part, here:

18 Daniel Otis, “Second homeless man dead as bitter cold envelops city” Toronto Star (January 2015) online: <http://www.thestar.com/news/gta/2015/01/06/second_homeless_man_dead_as_bitter_cold_envelops_city.html>. 19 Angela M. Cheung, Stephen W. Hwang, “Risk of death among homeless women: a cohort study and review of the literature” CMAJ (April 2004) online: <http://www.cmaj.ca/content/170/8/1243.full>. 20 Concluding Observations of the Human Rights Committee: Canada, CCPR/C/79/Add.105 (7 April 1999), para. 12.

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The State party should urgently respond to the crisis of homelessness by adopting positive measures as required by article 6 (1), including effective strategies with goals, timelines and independent monitoring and complaints procedures as recommended by the previous Special Rapporteur on Adequate Housing following his mission to Canada.

The State party should adopt a broader interpretation of Section 7 of the Charter of Rights and Freedoms, one that reflects interdependence.

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