Thank you, Mr. Chair.
Good afternoon, members of the committee. My name is Alain Pineau and I'm the national director of the Canadian Conference of the Arts. Thank you for giving me the opportunity to present our views on Bill C-470.
The CCA is the oldest and most broadly based cultural umbrella organization in Canada. The CCA provides a national forum for the entire arts, culture, and heritage community, from all disciplines and regions. Our membership reaches over 300,000 artists, creators, and cultural workers.
The CCA fully supports the objectives of transparency within the structures of charitable organizations in Canada, but it is our opinion that Bill C-470 is fundamentally unnecessary, intrusive, and ill-conceived. Like other members of Imagine Canada, we rejoice in the fact that the sponsor of the bill has proposed to drop the controversial cap on salaries. This suggestion was certainly the most intrusive aspect of the bill. While it may not affect many organizations in the cultural sector, salaries of over $250,000 are rarely found in our arts sector. We all object to this unjustified intervention of the government in the governance of civil society organizations.
In our view, the second aspect of the bill remains objectionable, even after the proposed amendment to establish a $100,000 floor on salaries to be made public. Again, this would not apply to many people or organizations in the arts sector, but it is our opinion that it remains intrusive and unjustified. A large number of organizations in the arts, culture, and heritage sector have the status of charitable organizations. However, the vast majority receive only a small percentage of their revenue from donations. Very few arts, culture, or heritage organizations receive even 10% of their revenue from charitable donations.
Take the CCA's own case. Over the past three years charitable donations have contributed a small but much needed 1% of the total revenue of our organization. People who give to an organization like ours do so because they support the work we do and want to help us pay the expenses related to our main activities. Our case is not unique in the arts, culture, and heritage sector. It is our position that even with a floor of $100,000, this clause in Bill C-470 would still constitute an unwarranted and unnecessary intrusion on Canadians' right to privacy.
Why do we think it unnecessary? Because the CCA believes that Revenue Canada already has measures in place to regulate non-profit spending. Canadian charities are already required to publicly account for their organizational activities and finances, including information on staff compensation. Form T3010 requires the provision of a substantial amount of information, including contact information, details about directors, detailed revenue and expenditure information, description of charitable programs, political activities, transfers to qualified organizations, and fundraising revenues and expenditure. Charities must also report compensation information on schedule 3 to form T3010, to include total number of full-time staff, total amount of staff compensation, and the total amount paid to part-time staff.
The information is available, but I guess we can agree with the Honourable Albina Guarnieri that this information may be difficult for Canadians to understand and access. We agree that all Canadians should have easy access to the information in order to be better informed on the operations of charities. But instead of approaching the problem of transparency by applying intrusive legislation onto charities, we suggest that this is an opportunity for this committee and interested members of Parliament to work with Revenue Canada to make the information on charities more easily accessible to a Canadian audience.