text:
Community economic development activities and charitable registration
Reference number
July 26, 2012
This guidance replaces Guide RC4143, Registered Charities: Community Economic Development Programs, issued on December 23, 1999.
For more information, watch our recorded webinar Community economic development activities and charitable registration.
Community economic development (CED) activities can be charitable when they further a charitable purpose.
Organizations that carry out CED activities may be eligible for charitable registration under the Income Tax Act if all their activities further charitable purposes.
Generally, CED activities involve improving economic opportunities and social conditions of an identified community.
CED activities may further charitable purposes that:
- relieve poverty
- advance education
- benefit the community in other ways the law regards as charitable
CED activities generally fall into five areas:
- activities that relieve unemployment
- grants and loans
- program-related investments
- social businesses for individuals with disabilities
- community land trusts
To be charitable, CED activities must be undertaken in a way that ensures that any resulting private benefit is incidental, meaning that it is necessary, reasonable, and not disproportionate to the public benefit that is delivered. If a private benefit is more than incidental, an organization can face sanctions or have its charitable registration revoked.
When CED activities are undertaken in areas of social and economic deprivation, it may be easier to show that a private benefit is incidental. Each situation will be evaluated in its own context.
Table of contents
- A. Introduction
- B. Community economic development in the charitable context
- C. Community economic development activities that further charitable purposes
- Activities that relieve unemployment
- Employment-related training
- Grants and loans to eligible beneficiaries
- Program-related investments
- Examples of program-related investments
- Requirements for program-related investments
- Program-related investments in the form of loans and loan guarantees
- Program-related investments in the form of share purchases
- Specialized intermediaries for program-related investments
- Accounting for loans and program-related investments
- Social businesses for individuals with disabilities
- Community land trusts
- D. Community economic development activities that promote commerce or industry
- E. Community economic development activities in areas of social and economic deprivation
- F. Appendix A: Terms and definitions
- Footnotes
A. Introduction
1. The Canada Revenue Agency's Charities Directorate registers charities under the Income Tax Act and ensures that registered charities continue to meet all associated requirements.
2. In this guidance, unless otherwise stated, the terms:
- "charity" and "registered charity" include all three types of registered charities as defined under the Income Tax Act: charitable organizations, public foundations, and private foundations
- "organization" includes applicants for registration as a charitable organization, a public foundation, or a private foundation, as well as already registered charities
3. This guidance explains the Charities Directorate's interpretation of the relevant common law (case law or court decisions) and legislation (the Income Tax Act). It sets out the criteria the Charities Directorate uses to determine whether an organization that engages in community economic development (CED) activities that further charitable purposes may be eligible for registration as a charity under the Income Tax Act. Charitable registration is one option for organizations. Please go to Is registration right for you? for more information about this topic.
4. An organization must meet a number of general requirements to qualify for registration under the Income Tax Act. Refer to Charities Directorate guidance for detailed information about other registration requirements, including the following:
- public benefit requirements
- political activities
- business activities
- operating through intermediaries
- complying with Canada's anti-terrorism legislation
5. This guidance provides general information only. All decisions about specific organizations are made individually, applying the law to the facts in each case. The facts may come from information the organization provides or from other information available to the Charities Directorate.
B. Community economic development in the charitable context
Key concepts
6. The law in Canada does not recognize community economic development (CED) as a charitable purpose. However, activities related to CED (CED activities) may be charitable when they directly further a charitable purpose.
7. CED refers to a wide variety of activities. Other terms that could describe similar activities include community capacity building, social enterprise, and social finance. In this guidance, CED activities may include activities associated with all such terms. For more information about these terms, see Appendix A .
8. Regardless of how an activity is labeled, it will only be charitable if it directly furthers a charitable purpose. Footnote 1
9. Many CED activities involve improving economic opportunities and social conditions of an identified community. A community is often defined geographically, but in this guidance it can also mean an identified group of eligible beneficiaries who share a common characteristic that results in an economic disadvantage. Sometimes, both characteristics will be present.
10. Organizations that conduct CED activities must make sure they meet the public benefit requirement, which prohibits the delivery of unacceptable private benefits. As a general rule, a private benefit is a charitable or non-charitable benefit provided to a person, entity or organization that is not a charitable beneficiary, or a benefit provided to a charitable beneficiary that exceeds what is considered to be charitable. Most of the time, an unacceptable private benefit is one that is not incidental to achieving a charitable purpose. A private benefit will usually be incidental if it is necessary, reasonable, and proportionate to the public benefit achieved. For more information, go to Policy statement CPS-024, Guidelines for registering a charity: Meeting the public benefit test.
C. Community economic development activities that further charitable purposes
11. CED activities may potentially further purposes that relieve poverty, advance education, or benefit the community in other ways the law regards as charitable. The following are examples of charitable purposes that can be furthered by CED activities:
- relieving poverty by relieving unemployment of the poor
- advancing education by providing employment-related training
- benefiting the community in a way the law regards as charitable by:
- relieving unemployment of individuals who are unemployed or facing a real prospect of imminent unemployment and are shown to need assistance Footnote 2
- relieving conditions associated with disability
- improving socio-economic conditions in areas of social and economic deprivation
- promoting commerce or industry
12. Each charitable purpose has specific requirements relating to eligible beneficiaries. Footnote 3 For example:
- for a purpose that relieves poverty, eligible beneficiaries must be poor
- for a purpose that relieves conditions associated with disability, eligible beneficiaries are individuals with conditions associated with the disability
- when unemployment is relieved to further a purpose beneficial to the community in a way the law regards as charitable, the beneficiaries must be unemployed or facing a real prospect of imminent unemployment and be shown to need assistance
13. The courts have not recognized "providing employment," or "helping people find employment" as charitable purposes in and of themselves when the beneficiary group is the general public. Footnote 4 However, either providing employment, or helping individuals find employment, could be a charitable activity if it directly furthers one of the charitable purposes listed in paragraph 11.
14. CED activities generally fall into five areas:
- activities that relieve unemployment
- grants and loans
- program-related investments
- social businesses for people with disabilities
- community land trusts
15. Depending on the purpose they further, different activities may be subject to different requirements. For example, activities that advance education must be sufficiently structured, meaning they have a teaching or learning component and involve a legitimate, targeted attempt to educate, Footnote 5 requirements that do not generally apply to activities that further other charitable purposes.
16. The following sections provide more details about activities within these five areas and the charitable purposes they can further.
Activities that relieve unemployment
17. Activities that relieve unemployment of individuals who are unemployed or facing a real prospect of imminent unemployment and are shown to need assistance may be charitable if they directly further one or more of the charitable purposes listed in paragraph 11.
18. Examples of activities that relieve unemployment include:
- providing employment-related training (see paragraph 21)
- providing career counselling
- providing referral services to appropriate agencies for assistance
- forming and facilitating mutual support groups for individuals seeking employment
- providing assistance with résumés or preparing for job interviews
- establishing lists of available jobs
- matching individuals who are unemployed or facing a real prospect of imminent unemployment and are shown to need assistance to appropriate employers
- providing funds to allow individuals who are unemployed or facing a real prospect of imminent unemployment and are shown to need assistance to attend job interviews or to relocate to get employment
- helping unemployed individuals to get employment insurance or other benefits to which they are legally entitled
19. Helping individuals who are underemployed to get a new job can be a charitable activity when it can be shown to further a charitable purpose, such as relieving poverty or relieving conditions associated with a disability.
20. When the emphasis is on helping employers recruit employees, this does not further a charitable purpose due to the delivery of a more than incidental private benefit to the employers.
Employment-related training
21. Generally, employment-related training must not be limited to a specific employer, because this could result in an unacceptable private benefit to the employer. Footnote 6 Exceptions may be possible in areas of social and economic deprivation (see paragraphs 84-91). For more information, go to Policy statement CPS-024, Guidelines for registering a charity: Meeting the public benefit test.
22. Examples of employment-related training activities for eligible beneficiaries include:
Employability training: developing the skills necessary to prepare for employment such as English or French as a second language, as well as life skills such as time management and interpersonal relations.
Entrepreneurial training: providing instruction on preparing a business plan, obtaining financing, bookkeeping, preparing financial statements, marketing, and government regulations.
On-the-job training: providing on-the-job training in vocational or work skills that enhance an individual's employability. These activities cannot simply provide individuals with employment or supply an employer with staff. The aim and result of the program must be to provide training, not jobs. To be acceptable, programs should feature the following characteristics:
- instruction is provided to complement the on-the-job training (before or during the on-the-job component)
- the participants are employed for a limited period of time
- the charity offers a job placement service to help graduates of the program find work in the labour force
- the proportion of workers from the beneficiary group in relation to the total number of employees is 70% or higher, but alternative ratios may be justifiable if considerable supervision is required
- the focus of the activity must be to further a charitable purpose, not to generate revenue Footnote 7
23. If these criteria are not met, the charity may be running an unrelated business, which is not permitted. For more information, go to Policy statement CPS-019, What is a related business?
Grants and loans to eligible beneficiaries
Individual development accounts
24. Providing individual development accounts (IDA) may be charitable if they directly further one or more of the charitable purposes listed in paragraph 11.
25. IDAs are savings accounts that are used only for a specific goal. The charity provides matching funds at a predetermined ratio (for example 2:1) to help eligible beneficiaries develop savings over a specific period. For example, a charity contributes two dollars for every dollar the individual saves. The individual then uses the amount saved for the agreed upon goal.
26. While IDAs are most commonly used to further poverty relief by relieving unemployment of the poor, they may also advance education by providing funds for employment-related training, or further a fourth category purpose such as relieving employment-related conditions associated with disability.
27. Examples of IDAs that may further charitable purposes include:
- funds to help a disabled individual modify his or her home in order to operate a home-based business
- funds to buy tools that an unemployed tradesperson needs to work
- funds for employment-related training, including post-secondary education
28. The organization must be able to provide its policy for ensuring that IDAs are used only to further charitable purposes. The policy should include the following information:
- the criteria for determining who is an eligible beneficiary of an IDA
- how the amount of the IDA is determined
- the acceptable uses for its IDAs
- when eligibility ceases based on predetermined criteria (for example, the recipient has finished school or has purchased equipment and is now employed and therefore no longer meets predetermined poverty criteria)
29. To avoid delivering more-than-incidental private benefit, a charity may grant only the amount needed to achieve the charitable purpose. A charity must be able to show that its grants do not exceed this amount.
Loans and loan guarantees
30. Providing loans, including micro-loans, and loan guarantees to eligible beneficiaries may be charitable if they directly further one or more of the charitable purposes listed in paragraph 11. For example, a loan or loan guarantee can help an eligible beneficiary attend courses to enhance employment-related skills.
31. Start-up loans and loan guarantees to establish businesses, including sole proprietorships or collective enterprises such as worker cooperatives, can be charitable if they directly further a charitable purpose. These loans and loan guarantees are typically accompanied by entrepreneurial training (see paragraph 22) and necessary support services.
32. However, providing loans, including start-up loans, and loan guarantees to promote entrepreneurship by, for example, helping entrepreneurs bring new and innovative ideas to the marketplace, or to promote business development, is generally not a charitable activity. These loans and loan guarantees typically fail to directly further a charitable purpose without delivering a more-than-incidental private benefit.
33. When loans, including start-up loans, and loan guarantees are provided to individuals to relieve poverty, and the recipient no longer meets the eligibility criteria, the loan or loan guarantee no longer furthers the charitable purpose. The balance of the loan should be repaid or the terms of the loan adjusted to market rates to ensure the non-qualifying beneficiary doesn't receive an undue private benefit.
34. The organization must be able to provide its policy that ensures that all loans and loan guarantees further its charitable purposes. The policy should include the following information:
- the criteria for determining eligible beneficiaries
- in the case of start-up loans for businesses, how it determines when a start-up business has become viable and no longer needs support. For example, the organization might consider a business to be viable when it can get financing from conventional sources
35. To avoid delivering a more-than-incidental private benefit, a charity may only loan or guarantee an amount needed to achieve the charitable purpose. Total loans or guarantees of less than $10,000 to eligible beneficiaries will generally be considered to meet this requirement; however, the determination will be fact-based in each case. For example, a smaller loan may achieve the same results in a developing economy that a $10,000 loan would achieve in the Canadian context.
36. A charity must be able to provide a rationale and justification to show that its loans or guarantees do not exceed the amount needed to achieve its charitable purpose. For more information about private benefit, go to Policy statement CPS-024, Guidelines for registering a charity: Meeting the public benefit test.
37. In most cases, interest rates are expected to be at or below fair market value to allow greater charitable benefits to be delivered. Footnote 8 However, there may be circumstances when a higher rate is justified. For example, a loan at above-market rates could be justified based on terms that allow the borrower to delay repayment. Flexibility may be as important a consideration as rate for some borrowers.
38. For information about accounting for loans, see paragraphs 61-68.
Program-related investments
39. Program-related investments (PRIs) may be charitable if they directly further one or more of the charitable purposes listed in paragraph 11. A PRI is an activity that directly furthers the investor charity's charitable purposes. Common types or forms of PRIs include:
- loans
- loan guarantees
- share purchases
- leases of land or buildings
40. A PRIs is not an investment in the conventional financial sense. While PRIs may generate a financial return, they are not made for that reason. A PRI usually involves the return, or potential return, of capital (funds or property) within a set period of time, but this is not a requirement. A PRI may also yield additional revenue for the investor charity (such as interest), but the yield of additional revenue can be below market rates.
41. A charity could often simply fund a PRI-related activity outright because it furthers one of its charitable purposes. However, a charity may decide to invest capital with the expectation of it being returned with or without yielding additional revenue for various reasons. For example, a PRI can increase the benefits a charity can provide when the invested capital or property is returned (such as repaying the principal or ending a lease), or yields additional revenue (such as interest on a loan) as these funds or facilities can be used or re-used to support other charitable activities.
Examples of program-related investments
42. Examples of PRIs include:
Example A
A charity that has a purpose to relieve poverty by providing essential amenities of life makes a PRI in the form of a fair market value purchase of shares of an arm's length corporation (a non-qualified donee Footnote 9 ) that operates a commercial apartment complex. This PRI is based on a written agreement that a proportionate number of units in the apartment complex are rented at reduced rates to poor individuals who satisfy the investor charity's appropriate poverty eligibility criteria. The terms of the agreement include ongoing monitoring and reporting provisions to ensure the charity maintains the necessary direction and control over its activity, which is to provide affordable rental housing to the poor.
Example B
A charity that has a purpose to relieve unemployment of individuals who are unemployed or facing a real prospect of imminent unemployment and are shown to need assistance by providing job skills training makes a PRI in the form of a low-interest loan to a not-for-profit entity (unconnected to the investor charity and a non-qualified donee). The not-for-profit entity provides job training programs on the charity's behalf. This PRI is based on a written agreement that the funds are used only to provide training to participants who meet the investor charity's appropriate eligibility criteria. The terms of the agreement include ongoing monitoring and reporting provisions to ensure the charity maintains the necessary direction and control over its activity.
Example C
A charity that has a purpose to advance education leases a building to an arm's length organization (a non-qualified donee) at less than fair market value. The arm's length organization teaches English or French as a second language to help students develop the skills necessary to prepare for employment. The lease agreement between the charity and the arm's length organization states that all students have to meet the investor charity's appropriate eligibility criteria. The terms of the agreement include ongoing monitoring and reporting provisions to ensure the charity maintains the necessary direction and control over its activity, which is to teach eligible beneficiaries the language skills necessary to prepare them for employment.
Requirements for program-related investments
43. A PRI must directly further a charity's stated charitable purposes.
44. According to the Income Tax Act, a registered charity can only use its resources (such as funds, personnel, and property) in two ways:
- for gifting funds to qualified donees
- for its own activities (those over which the charity maintains ongoing direction and control, and for which it can account for any resources invested)
45. For this reason, a PRI must:
- be made to a qualified donee
- if the recipient is a non-qualified donee, the PRI must be used for a program over which the investor charity maintains ongoing direction and control, so that the program is the investor charity's own activity
46. When a PRI is made for the program of a qualified donee, the investor charity does not need to retain direction and control over the resources invested. These PRIs are considered to generate gifts to the recipient qualified donees to the extent of the investment income foregone by the investor charity.
47. If a PRI is made for a program being carried out by a non-qualified donee, the investor charity must be able to prove that the arrangement meets the "own activities" requirements of the Income Tax Act. This means that the program the PRI relates to must be conducted under the charity's ongoing direction and control. In many cases, the recipient non-qualified donee will act as the intermediary of the investor charity.
48. For information about the types of arrangements an investor charity can use to establish the necessary direction and control, see the sections relating to working with intermediaries in Guidance CG-002, Canadian registered charities carrying out activities outside Canada, and Guidance CG-004, Using an intermediary to carry out a charity's activities within Canada. Footnote 10
49. A charity that makes a PRI to a non-qualified donee must show that any private benefit resulting from the PRI is incidental (necessary, reasonable, and not disproportionate to the resulting public benefit). For more information about private benefit, go to Policy statement CPS-024, Guidelines for registering a charity: Meeting the public benefit test.
50. If a charity cannot maintain direction and control over the activity carried out by a non-qualified donee, it cannot use a PRI. However, a charity could potentially invest in, or provide resources to, the non-qualified donee at market rates (as a form of conventional financial investment) provided the investment meets the investor charity's conventional investment requirements.
51. The charity must ensure it has appropriate exit mechanisms in place to allow it to: a) withdraw from a PRI; or b) convert the PRI to a regular investment, if the PRI no longer furthers its charitable purposes. Failing to do so may result in sanctions. Examples of exit mechanisms include:
for PRIs in the form of loans or leases, the exit mechanism is most often a condition that requires the immediate repayment of the loan or termination of the lease, or the conversion of the loan or lease to commercial terms. In the latter case, the loan or lease must subsequently be treated as an investment, not an activity that furthers a charitable purpose. The charity would be expected to get appropriate market rates of return on such an investment. Property not used in charitable programs or administration may be subject to the disbursement quota
for PRIs in the form of shares, subject to the laws governing the reduction of capital, the exit mechanism would likely be an arrangement by which the company initially issues shares that are redeemable in certain circumstances or by which it agrees to repurchase its own shares conditionally. Alternatively, a charity could declare that the investment is no longer a PRI, but has become a regular investment. In that case, the charity would be expected to get appropriate market rates of return on such an investment. Property not used in charitable programs or administration may be subject to the disbursement quota
52. Other forms of exit mechanisms may be used provided they satisfy the requirement that the charity is able to withdraw its investment when it can no longer ensure that its charitable purposes are being furthered.
53. The charity should have a written policy or other documentation explaining the relationship of each PRI to its purposes, and setting out the criteria or parameters it applies when making PRI decisions. If the PRI involves funding a non-qualified donee, supporting documentation to establish the necessary direction and control as outlined in paragraphs 47-48 should form part of the charity's books and records because the Charities Directorate may ask to see it during the application or audit processes.
54. The charity must also ensure that its PRIs meet all applicable trust, corporate, or other legal or regulatory requirements.
Program-related investments in the form of loans and loan guarantees
55. A charity Footnote 11 may make a PRI in the form of a loan. In most cases, interest rates are expected to be at or below fair market value so that greater charitable benefits can be delivered. Footnote 12 However, there may be circumstances when a higher interest rate is justified. For example, a loan at above-market rates could be justified based on other terms that allow the borrower to delay repayment. For some borrowers, flexibility may be as important a consideration as rate.
56. A charity may also make a PRI in the form of a loan guarantee to help another organization to obtain a loan. The guarantee must be for a loan that will further the investor charity's charitable purposes.
Program-related investments in the form of share purchases
57. A charitable organization may make a PRI in the form of share purchases. A public or private charitable foundation can also make a PRI in this form, but neither can acquire a controlling interest in a company. Footnote 13 Also, if a private foundation acquires more than 20% of any class of shares in a company, it might trigger divestment obligations and sanctions, including revocation of its charitable status. Footnote 14
58. Other legal limitations may apply to all charities because of the provisions in provincial and territorial legislation.
Specialized intermediaries for program-related investments
59. An investor charity may use an intermediary to carry out the program financed by the PRI on its behalf. The same requirements for maintaining direction and control over resources, avoiding non-incidental private benefit, and including exit mechanisms all apply. For more information about working through an intermediary, go to Guidance CG-002, Canadian registered charities carrying out activities outside Canada, and Guidance CG-004, Using an intermediary to carry out a charity's activities within Canada. Footnote 15
60. A specialized PRI intermediary that helps charities to make or manage PRIs could itself potentially qualify as a registered charity on the basis that it is promoting the efficiency and effectiveness of charities. For example, a property management organization that leases and manages only low-income housing properties owned by registered charities might qualify for charitable status. For more information, go to Policy statement CPS-026, Guidelines for the registration of umbrella organizations and title holding organizations.
Accounting for loans and program-related investments
61. When completing its annual information return (Form T3010, Registered Charity Information Return), a charity should include the outstanding amount of all loans and the value of all PRIs (loans, share purchases, and leases) in its total assets (section D, line 4200 Footnote 16 ) or accounts receivable from all others (Schedule 6, line 4120). Footnote 17
62. Charities should not include loaned funds and PRIs used for charitable activities in assets "not used in charitable programs or administration" when completing the T3010.
63. Charities that have to complete Schedule 6 of the T3010 must report all interest or other income that is earned from loans or PRIs at line 4580 – Total interest and investment income received or earned. Charities that have to complete section D must report all interest or other income that is earned from start-up loans or PRIs at line 4650 – Other amounts not already included in the amounts above.
64. If the charity has to complete Schedule 6, all amounts received (principal repaid, interest earned, disposition from shares, dividend income, etc.) have to be added to the total "property not used in charitable activities" (Schedule 6, lines 5900 and 5910) until such time as it is directly used again for charitable activities or administration.
65. If a portion of any loan is held by the loan recipient for future use, that portion has to be reported as "property not used in charitable activities."
66. A PRI in the form of a loan guarantee is cost-neutral. It is not a debt at the time the loan is guaranteed. If the borrower defaults on the loan, and the charity has to honour the guarantee, the charity will be considered to have incurred a debt. Once the debt has been incurred, the charity has to report the debt as a liability. Any principal and interest paid can be reported as a charitable or other type of expenditure, as applicable.
67. If the investor charity is unable to recover part or all of the principal of a loan, the unrecovered amount is a charitable or other expenditure of the investor charity, depending on the purpose of the loan.
68. When a charity fails to meet its disbursement quota requirement and the charity has made a loan or a PRI (in the form of a loan, a share purchase, or a lease), the Charities Directorate may consider any opportunity cost resulting from these activities as equivalent to an expenditure. In this situation, the opportunity costs of PRIs are calculated as follows:
- loans: the outstanding loan multiplied by the difference between the interest rate the investor charity could have earned if it invested the amount in T bills or GICs, and the interest rate the charity received
- share purchase: the difference between the return the investor charity could have realized had it invested in T bills or GICs and the actual return or loss from purchasing shares
- lease: the difference between the fair market value of the lease and the actual amount the investor charity received from the lease
Social businesses for individuals with disabilities
69. Operating social businesses Footnote 18 for individuals with disabilities Footnote 19 may be charitable when the businesses directly further one or more of the charitable purposes listed in paragraph 11. Social businesses differ from on-the-job training opportunities because they seek to provide permanent employment, not employment for a limited time.
70. A social business may provide services, sell goods, manufacture articles, or undertake other kinds of work. A social business may operate a retail outlet or send products manufactured in a workshop to a store.
71. Social businesses may directly employ eligible beneficiaries. They may also provide technical assistance, tools, materials, and marketing to eligible beneficiaries who use the workshop, but are self-employed.
72. To further a charitable purpose, a social business must have the following characteristics:
- the workforce is composed entirely of individuals with disabilities, with the exception of employees who provide necessary training and supervision
- the work is specifically chosen and structured to take into account the special needs of individuals with disabilities and to relieve conditions associated with those disabilities
73. The following characteristics, although not required, are generally expected:
- associated job-related training that enhances the general skills of the eligible beneficiaries
- significant involvement of eligible beneficiaries in managing and making decisions for the social business
74. A social business must focus on helping eligible beneficiaries and not on making a profit. For more information, go to Policy statement CPS-019, What is a related business?
Community land trusts
75. Operating a community land trust may be a charitable activity if it directly furthers one or more of the charitable purposes listed in paragraph 11.
76. A community land trust is set up to ensure that land will continue to be available for the benefit of a community. Generally, community land trusts operate by developing properties and leasing them to eligible beneficiaries. For example, an organization that creates a community land trust to provide housing for individuals who are poor or who have a disability may be eligible for registration as relieving poverty or conditions associated with disability.
D. Community economic development activities that promote commerce or industry
77. CED activities may be charitable when they promote commerce or industry for the public benefit. Footnote 20 Charities may conduct CED activities to promote a particular industry or trade such as agriculture, horticulture, or craftsmanship. However, the organization's purposes and activities must focus on enhancing an industry or trade as a whole for the benefit of the public, and not on advancing the interests of members of that industry.
78. Promoting a particular industry or trade will only be charitable if doing so results in a charitable benefit being provided to the public or a sufficient section of the public. Footnote 21 At common law, a charitable benefit must be recognizable and capable of being proved, and socially useful. To be recognizable and capable of being proved, a benefit must generally be tangible or objectively measurable. Benefits that are not tangible or objectively measurable must be shown to be valuable or approved by "the common understanding of enlightened opinion for the time being." Footnote 22 "The common understanding of enlightened opinion for the time being" may be proved through objective evidence of common or widespread acceptance by persons who are knowledgeable and informed about the particular subject or issue. To be socially useful, a benefit must have public value and a demonstrable impact on the public. Footnote 23 This means that the nature of the particular industry or trade must be such that its promotion results in a charitable benefit, and that charitable benefit must be delivered to the public.
79. Examples of the types of purposes that could enhance an industry as a whole and potentially deliver a charitable public benefit include those that:
- promote greater efficiencies within an industry, if those efficiencies benefit the general public
- promote and facilitate the achievement, preservation and maintenance of high standards of practice within an industry, if doing so benefits the general public Footnote 24
80. Examples of activities that further the purposes in paragraph 79 include:
- conducting research that will be publically disseminated to establish the socio-economic profile of a community, assess its socio-economic strengths and weaknesses, and identify potential economic opportunities. For more information, go to Guidance CPS 029, Research as a charitable activity
- holding public exhibitions of a community's agricultural products and services that include prizes being awarded to promote excellence and demonstrations being conducted to showcase new advances in technology and enable spectators to learn about the industry
- encouraging excellence in the products and services of an industry by holding industry-wide competitions, creating industry-wide standards, or developing and disseminating new scientific and technological knowledge related to that industry
81. Organizations often have difficulty promoting commerce or industry without delivering more-than-incidental private benefit to those engaged in the particular industries or trades. The public benefit cannot be too indirect, remote, or speculative as compared to a more direct or immediate private benefit, particularly where the direct benefit is to private persons, entities or businesses. Footnote 25
82. Objective evidence is used to determine whether a benefit to the public will result from promoting an industry. The non-expert opinions of the founders, directors, trustees, members or supporters of the organization are not relevant, and an expression of non-expert opinion or belief, or merely stating that a public benefit will result from a purpose, is not enough. Footnote 26
83. Examples of types of purposes that are not charitable as promoting commerce or industry because they do not deliver the required charitable benefit to the public include:
- promoting entrepreneurship by helping entrepreneurs bring new and innovative ideas to the marketplace
- promoting business development by providing funding (including start-up loans), and mentorship programs
E. Community economic development activities in areas of social and economic deprivation
84. CED activities may be charitable if they improve socio-economic conditions for the public benefit in an area of social and economic deprivation. Footnote 27
85. In this guidance, areas of social and economic deprivation (also known as deprived areas) are geographic communities that generally display high rates (at least 1.5 times the national average) of one or more of the following characteristics:
- unemployment for two or more consecutive years Footnote 28
- crime, including family violence
- health problems, including mental health issues, drug and alcohol addiction, and suicide
- children and youth at risk (taken into care or dropping out of school)
86. To deliver the required public benefit, the deprived area must be large enough for the beneficiaries to form a sufficient segment of the public.
87. An area that does not display these characteristics for four years in a row is no longer considered socially or economically deprived. When this happens, a charity whose activities were charitable solely because they were conducted in the deprived area has a further two years to wind up those activities.
88. Special considerations relating to the assessment of private benefit are generally allowed in deprived areas. This is because what is considered to be an acceptable incidental private benefit can vary depending on the context it occurs in. Footnote 29 The private benefit assessment involves considering the usual factors: whether a private benefit is necessary, reasonable, and not disproportionate to the public benefit achieved. However, what is necessary, reasonable, and not disproportionate is fact-based, and is determined taking into account the circumstances of the deprived area in question.
89. For example, it may be possible to establish a connection between a shortage of health care professionals and the social and economic deprivation in an area. If so, attracting health professionals to the deprived area by offering inducements (private benefits) might be a charitable activity that directly furthers the fourth category purpose of improving the socio-economic conditions in an area of social and economic deprivation. The organization has to show that the private benefit delivered to the health care professionals (such as providing low-rent clinic facilities or housing) is incidental in the particular case.
90. In deprived areas, preventing further unemployment by providing training to the employees of a specific company may be charitable, when it would otherwise deliver a more than incidental private benefit, if:
- without this training, the company would be forced to close or dismiss workers
- the training can be generally applied in the marketplace (such as literacy or computer skills), as opposed to training that is useful only to the specific employer Footnote 30
91. For more information on the restrictions on private benefit, see CPS-024: Guidelines for registering a charity: Meeting the public benefit test.
F. Appendix A: Terms and definitions
Community economic development has not been recognized as a charitable purpose in Canada. The Charities Directorate does not have official definitions for community economic development or other associated terms, and recognizes that there are no universally accepted definitions. The following definitions may be helpful to readers interested in considering the concepts further. They are provided for reference only and will not be used as determining factors in any registration or auditing processes.
Community economic development
"...is action by people locally to create economic opportunities and better social conditions, particularly for those who are most disadvantaged. CED promotes holistic approaches, addressing individual, community and regional levels, recognizing that these levels are interconnected."
Source: What is CED?, The Canadian CED Network
Social enterprise
"A social enterprise is generally understood to mean any organization or business that uses the market-oriented production and sale of goods and/or services to pursue a public benefit mission. This covers a broad spectrum of entities – from enterprising charities, non-profits, and co-operatives to social purpose businesses."
Source: Mobilizing Private Capital for Public Good (p.32), Canadian Task Force on Social Finance
Social finance
"Social finance uses standard financial tools and instruments to leverage the economic, social and environmental value created by organizations in the non-profit and for-profit sectors or in the hybrid space between them. These organizations are usually mission-driven and seek to maximize all three forms of value."
Source: Impact Investing / Social Finance, Carleton Centre for Community Innovation
Community capacity building
"…refers to the identification, strengthening and linking of your community's tangible resources, such as local service groups, and intangible resources like community spirit."
Source: Community Capacity Building: Ontario Healthy Communities Coalition
Footnote 1
Vancouver Society of Immigrant and Visible Minority Women v. M.N.R., [1999] 1 S.C.R. 10 (S.C.C.) (Vancouver Society), per Iacobucci J. at para. 152; it is the purpose an activity furthers, and not the character of the activity itself, that determines if it is of a charitable nature. And at para. 154: "In light of the preceding discussion regarding the construal of charitable activities, exclusively charitable activities would be those that directly further charitable purposes and not other, non-charitable, purposes."
Return to footnote referrer Footnote 2
In this context, eligible beneficiaries are those who do not have the resources or skills to help themselves.
Footnote 3
See, for example, Vancouver Society, supra note 1, where the Society's program included certain non-educational services for its students, such as networking, soliciting job opportunities, maintaining a job skills directory, liaising for accreditation of foreign credentials, and offering referral services. These were ruled to be non-charitable largely because those receiving them could have included those who were not eligible charitable beneficiaries.
Footnote 4
See, for example, Vancouver Society, supra note 1.
Footnote 5
The following statement from Vancouver Society, supra note 1, per Iacobucci J. at para. 171 summarizes the direction of the Court in this regard:
"That is not to say that education should be broadened beyond recognition, however. Even while advocating a more inclusive approach to education, the Ontario Law Reform Commission also cautioned against treating as educational those activities which, although they advance legitimate goods, do not include any actual teaching or learning component. … I would agree with that caution. To my mind, the threshold criterion for an educational activity must be some legitimate, targeted attempt at educating others, whether through formal or informal instruction, training, plans of self-study, or otherwise. Simply providing an opportunity for people to educate themselves, such as by making available materials with which this might be accomplished but need not be, is not enough. Neither is "educating" people about a particular point of view in a manner that might more aptly be described as persuasion or indoctrination. On the other hand, formal or traditional classroom instruction should not be a prerequisite, either. The point to be emphasized is that, in appropriate circumstances, an informal workshop or seminar on a certain practical topic or skill can be just as informative and educational as a course of classroom instruction in a traditional academic subject. The law ought to accommodate any legitimate form of education."
Footnote 6
See, for example, Re Leverhulme, [1943] 2 All ER 143 (Ch.D.) (Re Leverhulme).
Footnote 7
This is not to say that a charity cannot charge program participants or sell goods or services produced in the course of the program. See, for example, CIR v. Peebleshire Nursing Association, (1927) 11 T.C. 335; Everywoman's Health Centre Society (1988) v. Minister of National Revenue, [1991] 2 C.T.C. 320, [1992] 2 F.C. 52(F.C.A.) (Everywoman's Health Centre) and Charities Directorate Policy summary, CPS-024, Guidelines for registering a charity – Meeting the public benefit test.
Footnote 8
A charity may generally justify charging an interest rate that covers, but does not exceed, its own borrowing rate and administrative costs, plus a loan-loss provision that is supported by the charity's actual loan-loss experience. New charities can rely on the loan-loss experience of charities that operate similar programs.
Footnote 9
Qualified donees are organizations that can issue official donation receipts for gifts that corporations make to them, as listed in subsection 110.1(1)(a) the Income Tax Act, and individuals make to them as listed in subsection 118.1(1) the Income Tax Act.
Footnote 10
Private foundations may be restricted in terms of the types of arrangements they may enter into, based on, for example, the prohibitions against engaging in business activities and the excess business holding rules. Private foundations must ensure that any arrangements entered into when making a PRI through a non-qualified donee comply with all applicable legal requirements.
Footnote 11
Private foundations are restricted in that they are not permitted to engage in any business activities. While charitable organizations and public foundations can make a PRI that generates business income for the investor charity to the extent that the PRI does not become a collateral purpose, a private foundation is not permitted to invest in a PRI that generates business income for the private foundation because this would be considered to be carrying on a business. Whether any income generated by the PRI would be reported on account of business or property is a question of fact, and depends on the particulars of the arrangement, including the scope of the charity's involvement in the activity financed by the PRI and the extent to which it is structured to allow the charity to realize profits from the ongoing activities.
Footnote 12
See supra note 8.
Footnote 13
A charitable organization can retain control over the taxable corporation through share holdings or a power to nominate the board of directors as long as its own governing documents and provincial legislation allow it to do so. Charitable foundations (public or private) cannot acquire or maintain control of a corporation. This prohibition does not apply, however, to a foundation gaining control of a corporation by gift. Paragraph 149.1(12)(a) of the Income Tax Act defines "control" in this context as follows: "[A] corporation is controlled by a charitable foundation if more than 50% of the corporation's issued share capital, having full voting rights under all circumstances, belongs to the foundation, or the foundation and persons with whom the foundation does not deal at arm's length." However, foundations may acquire control of a corporation if they receive the shares as a gift and they have not previously "purchased or otherwise acquired for consideration more than 5% of the issued shares of any class of the capital stock of that corporation." The principles in note 11, supra, also apply to PRIs that are structured through share purchases.
Footnote 14
Footnote 15
Private foundations may be restricted in the types of arrangements they may enter into, based on, for example, the prohibitions against engaging in business activities and the excess business holding rules. Private foundations must make sure that any arrangements they enter into when making a PRI through a non-qualified donee comply with all applicable legal requirements.
Footnote 16
All line numbers are subject to change. Charities are responsible for ensuring that the information is recorded on the correct line.
Footnote 17
Until it is written off as uncollectable, the loan remains an account receivable.
Footnote 18
The previous version of the community economic development guidance referred to social businesses as "sheltered workshops."
Footnote 19
According to the Canadian Human Rights Act, R.S.C. 1985, c. H-6, s. 25: "disability" means any previous or existing mental or physical disability and includes disfigurement and previous or existing dependence on alcohol or a drug.
Footnote 20
See, for example, Crystal Palace Trustees v. Minister of Town and Country Planning, [1950] 2 All ER 857; IRC v. White and Others (re The Clerkenwell Green Association for Craftsmen), [1980] 55 TC 651, [1980] TR 155 (IRC v. White); Inland Revenue Comrs v. Yorkshire Agricultural Society, [1928] 1 KB 611, 97 LJKB 100, 138 LT 192
Footnote 21
For more information about charitable benefit, and about what will be considered to be the public or a sufficient section of the public, go to Policy statement CPS-024, Guidelines for registering a charity: Meeting the public benefit test.
Footnote 22
See, for example, Vancouver Society, supra note 1 per Gonthier J. (dissenting in the result) at para. 41, National Anti-Vivisection Society v. I.R.C.,[1948] A.C. 31 (HL) (National Anti-Vivisection Society) per Lord Wright at p. 47 and p. 49; Decision of the Charity Commissioners for England and Wales (17 November 1999) Application for Registration as a Charity by the Church of Scientology (England and Wales); Decision of the Charity Commission for England and Wales (August 15, 2000), Application for Registration of National Federation of Spiritual Healers (NFSH) Charitable Trust Limited; and Everywoman's Health Centre, supra note 7 per Decary J. at para. 16, indicating that Canadian courts have taken a cautious approach, being "ill-equipped" to "assess public consensus, which is a fragile and volatile concept."
Footnote 23
See, for example, National Antivivisection Society, supra note 22 per Lord Wright at p. 49: "The law may well say that quite apart from any question of balancing values, an assumed prospect, or possibility of gain so vague, intangible and remote cannot justly be treated as a benefit to humanity, and that the appellant cannot get into the class of charities at all unless it can establish that benefit."; In re Shaw decd, [1957] 1 WLR 729; Gilmour v. Coats et al,[1949] A.C. 426 (HL) per Lord Simonds at pp. 446-447; McGovern v. AG, [1981] 3 All ER 493; Re Hummeltenberg, Beatty v London Spiritualistic Alliance, [1923] All ER Rep at p. 51, [1923] 1 Ch 237 per Lord Russell of Killowen (then Russell J.) at p. 242 (Re Hummeltenberg); Re Pinion (deceased); Westminster Bank v. Pinion and another, [1965] Ch 85, [1964] 1 All ER 890 (Re Pinion); In re Grove-Grady, Plowden v. Lawrence, [1929] 1 Ch. 557; In re Price, Midland Bank Executor and Trustee Company, Limited v. Harwood, [1943] Ch. 422
Footnote 24
See, for example, IRC v White, supra note 20; Construction Industry Training Board v Attorney General, [1971] 1 W.L.R. 1303; and Whitehall and Industry Trust, [1990] Ch Com Rep 8 at para. 39
Footnote 25
See, for example, Inland Revenue Commissioners v. Oldham Training and Enterprise Council, [1996] STC 1218, 69 TC 231, [1996] BTC 539 (Oldham TEC) and Canterbury Development Corporation v. Charities Commission; Canterbury Development Corporation Trust v. Charities Commission; CEDF Trustee Limited As Trustee of the Canterbury Economic Development Fund v. Charities Commission, [2010] NZHC 331 (Canterbury Development Corporation); Hadaway v. Hadaway, [1954] 1 W.L.R. 16 (P.C.); Independent Schools Council v. Charity Commission for England and Wales; Attorney General v. Charity Commission for England and Wales and another, [2011] UKUT 421 (TCC); and Re Co-operative College of Canada et al. and Saskatchewan Human Rights Commission, (1975) 64 D.L.R. (3d) 531
Footnote 26
See, for example, Re Hummeltenberg, supra note 23, per Lord Russell of Killowen (then Russell J.) at p. 242; Re Pinion, supra note 23, per Harmon L.J. at pp. 893-894; Re Shaw's Will Trusts, National Provincial Bank Ltd v. National City Bank Ltd., [1952] 1 All ER 49, [1952] Ch 163
Footnote 27
Formerly referred to as "economically challenged communities" (ECCs) in RC4143 Registered Charities: Community Economic Development Programs.
Footnote 28
Labour force participation may be used as an alternative to the unemployment rate.
Footnote 29
See, for example, Oldham TEC and Canterbury Development Corporation, supra note 25; and Policy statement CPS-024: Guidelines for registering a charity: Meeting the public benefit test.
Footnote 30
Re Leverhulme, supra note 6
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At the Annual Meeting of the Members of Oklahoma Historical Society, held January 23, 1929, Mrs. Jessie R. Moore gave notice
that she would at the next annual meeting of said Society; To wit, January 23, 1930, present an amendment to the Constitution
setting aside the present method of electing the Board of Directors, which is as follows:
"Five members of the Board of Directors to serve for a term of five years or until their successors shall have been elected
and qualified, shall annually be elected by ballot from the members of the Society in the following manner:
Between the first and tenth of January of each year the secretary and treasurer shall prepare and have printed at the expense
of the Society ballots containing all names of the five directors whose terms will expire during that year, unless otherwise
directed in writing by such director, and also names of such other members of the Society as may be petitioned thereto in
writing to be filed with the secretary by the first day of each year by twenty-five of its members at said time entitled to
vote on such matter, such ballot shall be by the secretary duly mailed to the address of each member of said Society, who
shall cross or mark out all of the names on such ballot except such as he or she may desire to vote for, not to exceed five,
and write his or her name on such ballot on the opposite side and then duly mail same to the secretary of the Historical Society,
at Oklahoma City, Oklahoma. On the fourth Tuesday in January following or as soon thereafter as practicable the president,
vice-presidents, secretary and treasurer shall meet and open said ballots, counting same and retaining the envelopes and ballots
in a safe place until the regular annual meeting when the result of said ballots shall be announced, the five receiving the
highest vote, provided each receives a majority of all the votes cast to be declared elected by said Society, provided where
a majority of those voting has not been received for such place the annual meeting shall proceed to fill such places by balloting
as to such two names having received the highest vote for such position, provided further that in instances where only five
names are hereunder placed on such ballot same
shall not be mailed out but such fact certified jointly by the secretary and treasurer to the next annual meeting, and said
five members by such meeting declared elected."
And adopt the method originally provided in the constitution adopted in 1922.
Signed, Mrs. Jessie R. Moore.
At the January 23, 1929 meeting of the members of the Historical Society, Judge R. L. Williams gave notice that he would at
the next annual meeting present an amendment to the constitution requiring a referendum on all future amendments to the constitution
and by-laws of the Society.
(Signed) R. L. WILLIAMS.
A meeting of the Board of Directors of the Oklahoma Historical Society was held August 2, 1929, in the Library of the Society
with the following members present: Judge Thomas H. Doyle, vice-president, presiding, Judge R. L. Williams, Judge Phil D.
Brewer, William S. Key, D. W. Peery, Jasper Sipes, and Judge W. A. Ledbetter.
Judge Doyle and Judge Williams, on the part of the committee appointed at the Board Meeting August 1, 1929, to confer with
the Board of Affairs in regard to increases of salaries, reported that the Board of Affairs had agreed to an increase of the
salary of the chief clerk from $1320.00 to $1500.00 per year and an increase in the salary of the file clerk from $1320.00
to $1500.00 per year and declined to agree to any further increases for the present, but agreed that when the new building
was completed and the Historical Society was housed in the new building that said Board of Affairs would be glad to take up
further increases as to salaries.
Mr. Sipes moved that the salary of the chief clerk be increased from $1320.00 to $1500.00 per year and that the salary of
the file clerk be increased from $1320.00 to $1500.00 per year. Motion was seconded by Mr. Peery and carried.
Judge Thomas H. Doyle,
Vice-President, presiding.
Meeting adjourned.
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George Parsons Jr. Sociology Major, Class of 1989 TU alumnus George Parsons believes in sharing the knowledge and life skills he learned in his time on the street with the Baltimore Police Department with future generations. The mission of his new book, "Passing the Baton," sets out to do just that. The book gives a first-hand account of the experiences, traditions and camaraderie behind his 24-year career in criminal justice. Some of the stories are serious, some are humorous, but all paint a picture of his years and experiences protecting the streets of Baltimore. Parsons joined the Baltimore Police Department in 1973 after four years of military service in the Navy. His career in criminal justice included service in the arson, marine, and the K-9 unit (with his beloved police-dog Kurt.) Parsons wrote the book to carry on the history and tradition of the nightstick - or baton - and to share stories from his years on the force. "It's my way of reaching beyond classroom instruction and giving advice to future officers regarding police life and the importance of teamwork," Parsons said. "I also wanted to share the history of what was once considered a crucial part of an officer's communication, defense and initiation -- the baton." Parsons' retired in 1992 and eventually moved to Florida where he currently teaches criminal justice at Saint Johns River Community College. He hopes his efforts will help young men and women realize their dreams of a career in law enforcement. To learn more about George Parsons, Jr. please click here.
Let's TalkThe Towson Fund Phonathon student callers want to talk to you! These students come from all backgrounds and are studying in a range of disciplines, but they all have at least one thing in common--they love Towson! Our students are going to be calling to ask for your annual gift to the university and also to keep you up-to-date about what is happening on campus. We hope you'll pick up the phone and allow them to share their enthusiasm with you. Tell them about your experience at Towson, and ask them about theirs. Let them answer your questions about the university and inform you of upcoming reunions and events. As you talk with them, we hope you'll also make a gift. State support continues to decline, and our student callers play a major role in helping to bridge the gap by encouraging gifts to scholarships, faculty professional development, and the programs you care about the most at Towson. The Phonathon students want to give you the opportunity to reconnect with the university this spring. We hope you'll take their call!
Culminating the 2010 PlanAs a result of focusing our efforts over the past six years on initiatives that support the 23 goals of the Towson University 2010 strategic plan, Towson University repeatedly received national attention for our value, academic quality, and outreach. Some of the highlights include: a U.S. News and World Report ranking TU in the top eight among master's institutions in the North; a 2009 Princeton Review top 50 Best Value public institution; a 2008 President's Higher Education Community Service Honor Roll Honoree; a 2008 Carnegie Foundation Community Engagement Classification for Curricular Engagement, Outreach, and Partnerships; a Kiplinger's Personal Finance magazine top 100 best value among public colleges; a 2010 GI Jobs magazine designation as a Military-Friendly School, to name a few.
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Deshpande, MD and Balaji, S and Milton, SG (1994) Laminar Flow Fields Three-Dimensional Cavity. Technical Report. National Aerospace Laboratories, Bangalore, India.Full text available as:
Restricted to Archive staff only
Download (3769Kb)
Flow in a cubical parallelepiped generated by the motion of one of its walls has been carried out for three values of Reynolds number 100, 400 and 1000.There has been very good agreement between our results and other computations done by a different method. Flow was found to reach an asymptotic steady state and retain symmetry about the mid Z-plane. Flow is characterised by a primary vortex two secondary vorticies and complex three dimensional separation and reattachment and differs qualitiatively from the two dimensional flow. The pressure on the top moving plate is very samll expect it has a high value near the top downstream conrner. Its variation in the bulk of the fluid is very small specially in the Z-direction.
|Item Type:
|Proj.Doc/Technical Report (Technical Report)
|Uncontrolled Keywords:
|Navier Stokes equations;Driven cavity;Laminar fields
|AERONAUTICS > Research and Support Facilities (Air)
|Computational and Theoretical Fluid Dynamics Division, Computational and Theoretical Fluid Dynamics Division, Computational and Theoretical Fluid Dynamics Division
|Depositing User:
|Mrs Manoranjitha M D
|Date Deposited:
|25 Apr 2006
|Last Modified:
|18 Aug 2015 13:13
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The residents of a To Kwa Wan tenement deemed unsafe may be able to stay in their homes, but they will still have to vacate them for three weeks.
The Buildings Department acceded to residents' demands yesterday by postponing the demolition of what it classes as dangerous balconies, while the whole building is investigated.
But residents and shop owners at 51 Kai Ming Street are still angry at the three-week eviction to allow further investigation of the tenement's main structure. They vowed to defy the closure order to be obtained by the department today.
Urban Renewal Authority chairman Victor So Hing-woh visited the site yesterday.
If the authority steps in and compensates the residents in the next three weeks, they will not have to move until the whole block is demolished. If not, they will have to move back home and await the investigation results. The department's spokeswoman said the amended plan was a result of meetings with the residents over the past few days.
Under the new plan, buildings officials will defer the demolition of the balconies until they complete the investigation of the tenement's main structure. "If both are found dangerous, we can demolish them in one go. It will be less disturbing to residents," the spokeswoman said.
The revised plan also shortens the eviction period from five months to about three weeks as the department will just strengthen support of both the balconies and the main structure as a temporary measure. It will also separate the balconies from the main structure to prevent residents from using the fragile structures.
Wong Yuet-sau, who runs a laundry on the tenement's ground floor, said the government had mentioned nothing about how shop tenants would be resettled.
"I will not leave unless they carry me out ... all I have is here in the shop and my business is getting steadily better at last," Wong said, adding that she would open the shop as usual next Monday.
"I will lose all my customers even if the shop is closed for more than a week," she said.
One Kowloon City district councillor is also dissatisfied with the plan. "If residents are allowed to stay, why should they [the department] obtain a closure order?" Pun Chi-man said.
"Why can't we wait for the authority to step in and redevelop the site? The building could become even more dangerous after heavy machines are used to take samples."
The condition of two tenements with the same type of balconies at 21 and 23 Kai Ming Street are also poor.
A reporter who visited the tenements found that No 21 contained six flats but these were subdivided and housed 16 households. There were also three dwellings on the rooftop. At least three out of the six storeys were subdivided, adding extra stress on the 56-year-old building. At No 23, all flats except those on the fifth floor were subdivided.


text:
A CONTROVERSIAL trial of a ''brain training'' program for Catholic school students with learning difficulties has been slammed by neuroscientists for misleading parents.
The Catholic Education Office in Sydney has targeted 20 high school students in years 9 and 10 to undertake the Arrowsmith program next school year.
If successful, it will be offered to thousands of students in younger grades. Parents will pay $8000 for two years for the program on top of normal school fees.
But neuroscientists have criticised the trial for misleading parents into believing it is based on scientific proof.
"Their claims of success is anecdotal and not the same as a refereed journal or a randomised control trial," a neuroscientist from the Florey Institute in Melbourne, Dr Emma Burrows, said.
The Canadian educator Barbara Arrowsmith Young devised the program 30 years ago based on what she claimed to be neuroscientific research. But Dr Burrows said its claims to be research-based were bogus. "Worryingly, neuroscientists are not involved in it and I don't see any prominent scientists endorsing it," she said.
Last month, Dr Burrows directly confronted Ms Arrowsmith Young about her claim. "Her answer was she hadn't engaged any neuroscientist to do tests. But I hope she soon will."
Ms Arrowsmith Young said she was on the verge of working with neuroscientists to examine how her program changed the brain.
''In the discussions they recognise that measurable change can occur in the brain as a result of the cognitive stimulation resulting from the Arrowsmith program," she told Fairfax Media from Canada.
The director of curriculum for the Sydney diocese, Seamus O'Grady, defended the program, saying scientists sought objective proof but certain things could not be easily explained.
"We've been doing the same thing for hundreds of years and for some there's no improvement," he said. "I'd like critics to meet the parents worried about their kids. I tell them we're not offering a magic bullet but it's something new to try."
Correction: The original version of this story said the Arrowsmith program would cost $16,000 for two years.


text:
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<!DOCTYPE HTML PUBLIC "-//W3C//DTD HTML 4.0 Transitional//EN">  <META http-equiv=Content-Type content="text/html; charset=utf-8"> <META content="MSHTML 6.00.6000.16705" name=GENERATOR>
Bill Leeper is probably correct. The Ozc Rally 2 drive ($23 for 8 GB) is very fast, per Ocz 32 MB/s read and half that for write. I was taken by SanDisk's claim that Cruzer Micro ($30 for 9 GB) is "ReadyBoost" enhanced. My bad! Now I see SanDisk leaves the R/W rates blank in their product comparison chart http://u3.sandisk.com/CompareU3_drives.html .

----- Original Message -----
From: Bill Leeper

To: PC-BSD Testing list

Sent: Monday, September 08, 2008 9:27 PM

Subject: Re: [PC-BSD Testing] More on: Beta 1 balky using 8GB Thumb,contention issue?

I can confirm your observations on the thumb drive installations. But
I would lay it more to the poor read/write speed of a standard flash
drive. I intend to pick up a high speed flash drive in a month or two
and try it with that. I would suspect that with a 16 GB high speed
flash drive it should do much better.

On Sep 8, 2008, at 4:55 PM, Peter Brewster wrote:

> Some investigation -
>
> 1) Confirmed that Xubuntu on a thumb boots and runs well. What I
> thought was a minor balk is Xubuntu giving to much time to grunt
> work and not enough priority to human interface.
>
> 2) Confirmed that beta-1 takes a long time to boot from a thumb
> drive and then runs in a very balky manor. Operations are
> eventually correct but system is not usable.
>
> 3) Installed a 7200 rpm disk. Beta-1 install took about 20 minutes
> vs. three hours to SanDisk thumb. Operation was very nice from the
> first start. Ksysguard showed similar cpu and memory usage but
> about 10 fewer processes using disk vs. thumb (137 vs. 147.)
>
> Bottom line: I'll give up on the thumb drive for PCBSD . . at least
> for now.
>
> ----- Original Message -----
> From: Peter Brewster
> To: email@example.com
> Sent: Sunday, September 07, 2008 6:26 PM
> Subject: Beta 1 balky using 8GB Thumb, contention issue?
>
> System is 2.8 MHz Celeron with .75 GB RAM, no hard drive, USB 2.0.
>
> 1) System had been in use with Xububtu on an 8 GB Ocz thumb. Very
> nice except an occasional one to two second "balk" when launching a
> new application or scrolling in Firefox.
>
> 2) Removed Ocz and plugged in a new SanDisk thumb, fresh from
> package. Tried to install from net. DHCP was OK and target FTP was
> correct. File system went in OK. Looks like install died on first
> file needed. Gave that up.
>
> 3) Burned a three-CD beta-1 set. Installed with Firefox, Office
> and Development selected on third CD. Install took about three
> hours but went OK. However from the first reboot some operations
> took several minutes, either to launch or to so something simple
> such as pull down a menu. But the actions generally seemed correct
> if I waited long enough. Now and then a launch would just get lost
> - including that doggone bouncing thing. The thumb drive had
> about 900 MB free. System was basically unusable.
>
> 4) Removed the SanDisk thumb and WinXP formatted it. (This left
> the U3 partition of 65 MB. That's OK.) Reinstalled just the two
> CDs. Took about two-plus hours. Now KDisk Free shows /dev/da0s1a
> as 76% used with 1.8 GB free. /dev/md0 is 8% used with 700 MB
> free. This looks OK to me. However there is no apparent change in
> the balky behavior. I notice that often, while waiting seconds to
> minutes for some function to appear, clicking on something else will
> cause the first item to happen. I've seen this behavior when
> installing very fast disks on systems that worked well with slower
> disks - usually resolved by paying attention to relative
> priorities. So system is still not usable.
>
> Kris - KDisk also shows a line entry "devfs ? 1 KB 100% used 0
> free" and the thermometer is filled with red. No slashes around
> devfs. I have no idea what that is about and don't know if it is a
> concern.
>
> Peter Brewster
>
>
>
> No virus found in this outgoing message.
> Checked by AVG - http://www.avg.com
> Version: 8.0.169 / Virus Database: 270.6.17/1657 - Release Date:
> 9/6/2008 8:07 PM
> _______________________________________________
> Testing mailing list
> firstname.lastname@example.com
> http://lists.pcbsd.org/mailman/listinfo/testing

Computers can be fun again
 format C:\
 Alternatives are out there

_______________________________________________
Testing mailing list
email@example.com
http://lists.pcbsd.org/mailman/listinfo/testing

No virus found in this incoming message.
Checked by AVG - http://www.avg.com
Version: 8.0.169 / Virus Database: 270.6.17/1657 - Release Date: 9/6/2008 8:07 PM


text:
Facebook CEO Hit With Billion Dollar Tax Bill
(Menlo Park, CA) -- Facebook CEO Mark Zuckerberg's wallet may be a little lighter following a billion-dollar tax bill related to the social network's initial public offering.
He bought 60 million options on the first day of the IPO at a rock bottom price.
The IRS treats the value of those shares as income whether they're sold or not. Current state and federal tax rates pushed that bill to more than the billion-dollar mark.


text: Arthur, The best thing I've found is to dig up the ERS for PBS. You should be able to google for it, I'm not sure if there is a link on the cluster resources site for it or not. It provides pretty good descriptions of the functions that are available. The other resource I always end up using are the man pages around attributes (man pbs_job_attributes, etc). Since the entire API takes lists of structs of job/server/etc attributes, you'll need to know those pretty well. Nate "Arthur Yuldashev" <arthur at mail.rb.ru> Sent by: torqueusers-bounces at supercluster.org 24-Jan-2007 05:21 To torqueusers at supercluster.org, torquedev at supercluster.org cc Subject [torqueusers] Torque API Documentation *This message was transferred with a trial version of CommuniGate(r) Pro* Good day! Where can I get guide or documentation on programming using Torque(PBS) API if something exists in this area. Arthur _______________________________________________ torqueusers mailing list torqueusers at supercluster.org http://www.supercluster.org/mailman/listinfo/torqueusers -------------- next part -------------- An HTML attachment was scrubbed... URL: http://www.supercluster.org/pipermail/torqueusers/attachments/20070124/2e367ee8/attachment.html


text:
[Date Index]
[Thread Index]
[Author Index]
Importing tab-delimited data files?
I create a text file "filedata" with the following content using a text
editor, with tabs between each number or string (5 tabs per line), and
no content -- not even a space, just successive adjacent tabs -- in the
empty slots.
(The columns should line up if your reader uses monospaced type.)
11 aaa 22 bbb 33 ccc
22 bbb 33 ccc
33 ccc
Opening Mathematica and using !!filedata reproduces exactly same thing:
11 aaa 22 bbb 33 ccc
22 bbb 33 ccc
33 ccc
Trying to follow this with
fileDataAsViewed = !!fildata
fileDataAsViewed = %
doesn't work, however.
Using the Mathematica expression
Import["datafile", "Table",
11 aaa 22 bbb 33 ccc
22 bbb 33 ccc
33 ccc
Recreating the text file with a space between the tabs in the empty
slots and applying the same Import[ ] expression, however, gives the
"right" answer:
11 aaa 22 bbb 33 ccc
22 bbb 33 ccc
33 ccc
I suppose this is not exactly unexpected. The problem is, the app that
creates the (much larger) tab-delimited filedata text file I really want
to load into a Mathematica Table creates numerous blank cells, i.e.
adjacent and unspaced tabs. I guess I'll just have to go at it with a
smart text editor and separate adjacent tabs before trying to load it.


text:
PAZ: Fandango Urbano workshops
La Peña Cultural Center
Tuesday, June 17, 2014 from 6:00 PM to 10:00 PM (PDT)
Who's Going
San Francisco, California
London, United Kingdom
Florence, Italy
Event Details
PAZ: Fandango Urbano
Workshops: 6/5-6/19
RSVP to the Facebook event page.
Show at 7pm, Fandango at 9pm
$20 Adv, $25 Door
PAZ: Fandango Urbano will create new community sones jarochos (music and dance!). The new sones will: be based on the Bay Area experience, both historical and contemporary; have universal themes; be created with community input and in such a way that invites others to continue to add to them over time.
PAZ: Fandango Urbano is putting these sones together in three stages:
1. In workshops and convivios (June 3-19), we'll collect material for these new sones. In a convivio with los jornaleros, for example, soneros arrive at places where large groups of day workers, mostly Latino immigrants, gather in hopes to get work for the day. The wait is grueling and can prove to be fruitless. In the convivio, we hang out sharing food, music, singing, dancing and listen to each other's stories and experiences. Some of these convivios have already been taking place and varios soneros have participated in them.
2. In Creative Labs, local son jarocho artists will work closely with international artists to create new sones in the son jarocho tradition. Local son jarocho artists include Artemio Posadas, Kamakshi (lead singer of the band FUGA!) and María de la Rosa. International artists include Rubí Oseguera Rueda, Patricio Hidalgo Belli, and Liche Oseguera Rueda who are all confirmed to the Project.
3. Fandango? POR SUPUESTO! The project will culminate in a concert and a fandango where the new sones will be debuted. Saturday, June 21 at La Peña is slated for these events.
About the participating artists (Pictured from top to bottom):
Lead artist: Maria de la Rosa
Maria de la Rosa has a long and productive working relationship with La Peña while developing the first phase of the PAZ project in 2011. She completed two traditional son projects with La Peña including an evening concert highlighting the poetry of son, including son jarocho with master musicians. She has worked as a Mexican traditional folk artist for over twenty-five years and has received numerous awards for her work as a choreographer and performer. María, as a musician, now maintains a music ensemble that, in three short years, has performed at such venues as La Peña, the Mexican Heritage Plaza, Yerba Buena Gardens and the De Young Museum for the closing of the Olmec Exhibit and under the auspices of the Mexican Consulate of San Francisco. She is an arts and education specialist at the East Bay Center for the Performing Arts and a consultant to the San Francisco Son Jarocho Festival.
Rubí studied Social Anthropology at the Universidad Veracruzana. Since 2009 she has been dedicated to the creation and production of stage productions, especially with the subject of music and dance traditional peoples of Mexico. Her works have been presented in various parts of the Mexican Republic in collaboration with institutions and artists is varied areas. She is the director of the project and dancers of Cantadoras Fandango Jarocho which aims to present and link musicians and popular artists.
Felix "Liche" Oseguera is a luthier and master musician with years of experience in new music composition. He is one of the founding members of Chuchumbe, one of the most recognized and well regarded son jarocho ensembles. One of his recent compositions was featured on the Grammy nominated album "Electro-Jarocho" by Sistema Bomb.
With his BA from the Centro de Bachillerato Tecnologico y Agropecuario (Veracruz, Mexico),Patricio Hidalgo Belli is a renowned composer, performer, teacher and scholar. He specializes in son jarocho and the traditional zapateado of the fandango dance, in addition to the history and craftsmanship of the son jarocho instruments. Mr. Hidalgo is an accomplished musician who has toured throughout Mexico, the United States, Europe, and Latin America and has appeared in Canada, China, Morocco, Cuba, Israel and Singapore.
Artemio Posadas received his BA in Humanities from the University of San Luis Potosi in his native city. He is a master Mexican Folklorist who has mastered a wide variety of traditional instruments. He specializes in Huastecan and Jarocho music and dance; as a scholar he researches regional cultural traditions for an organization he founded, Instituto Tamunal. Since 1973, Artemio has performed extensively at folkloric festivals and events throughout the US and Canada. He has been internationally recognized for his instrumental role in the development of regional Mexican music and dance in California.
Click to read this great article from one of our media sponsors, El Mensajero.
Special thanks to our Indiegogo funders for their help in making this project happen!
PAZ: Fandango Urbano has been commissioned by La Peña Cultural Center with support from National Performance Network.
When & Where
La Pena Cultural Center
3105 Shattuck Ave
Tuesday, June 17, 2014 from 6:00 PM to 10:00 PM (PDT)
Add to my calendar
La Peña Cultural Center
Email: email@example.com
Website: http://lapena.org
Phone: (510) 849-2568


text:
As Bruce Willis was preparing for his wedding day, his ex-wife Demi Moore was wearing a white bikini steaming her current hubby's suit.
We know this since Ashton Kutcher sent out photos of his wife's bikini butt to the world on his Twitter page.
"Shhh!, don't tell wifey," Kutcher sent in a tweet on Saturday morning.
Some 15 minutes earlier, Kutcher had sent along word: "watching my wife steam my suit while wearing a bikini. I love God!" And if further clarification was needed he added: "I'm not wearing the bikini, she is. That's what makes it so glorious."
And how did Demi take the news of this photo being circulated? "He's such a sneak," she said on her Twitter page. "And while I was steaming his suit."
Don't know about you, but we just cannot wait for Nude Vacuuming day at their house.
It was clearly a mellow vibe for the intimate affair for Willis and wife actress Emma Heming at Willis' home in Parrot Cay, Turks & Caicos. We're presuming his amicable ex-wife put something different on for the actual wedding. Also present at the event were Moore and Willis' daughters Rumor Willis, 20, Scout, 17 and Tallullah Belle, 15.
The wedding follows Willis' 54th birthday on Thursday. Heming is 32.
Willis wedding, we get the gift. What did you think of the Twitter post? Let us know in comments below.


text:
Although no longer in production, we still stock a very good selection
of Anna-Perenna plates illustrating the work of nationally aclaimed artist,
P Buckley Moss. Pat has produced limited edition prints, etchings, and
originals from her studio in Waynesboro, Virginia. Her artwork has been
recreated as needleart, porcelain ornaments and collectors plates.


text:
Introductory Lecture and Objectives
Introductory Lecture
A futuristic tale, The Giver subtly and convincingly warns us of the unintended consequences of "Sameness"—of communities that lack any sharp edges, of societies that root out and eradicate difference, and of lives lived without any reference to those that came before. Indeed, the role of memory—how and what we remember and how it shapes our lives—is a central theme Lois Lowry set out to explore in The Giver, a young adult novel awarded the prestigious Newbery Medal in 1994.
In accepting the award, Lowry spoke of the memories that helped form The Giver:
A spring, perhaps, at the beginning, bubbling up from the earth; then a trickle from a glacier; a mountain stream entering farther along; and each tributary bringing with it the collected bits and pieces from the past.
Lowry recounts a classmate in college, an outsider whom she and her friends ostracized for her difference; she remembers a painter she met who could "see" color differently than she could, noting that he later went blind. She thinks of her aged father looking at a photograph of her deceased sister, spared the pain of remembering his daughter's death. These are some of the tributaries of Lowry's past that helped form The Giver.
Indeed, it is perhaps Lowry's own self-awareness that makes this book so powerful. Drawing from her past experiences, Lowry brilliantly and subtly demonstrates how easy it is for our everyday choices— made with an eye only toward convenience and predictability—to prove harmful. Often without meaning to, we begin to make decisions and take actions to exert control, eradicate individuality, and neaten the messy margins of emotion and passion. Perhaps the most extreme example of such behavior is selective euthanasia, a highly charged topic Lowry addresses and which ironically has made The Giver a frequent target for censors; it is often banned from school reading lists.
The end result of embracing "Sameness," Lowry warns, could be to create a society like Jonas's. On the cusp of adulthood, Jonas and his friends, Asher and Fiona, ride their bicycles about town largely worry free, going from school to meaningful volunteer work with ease. Even the occasional scraped knee is easily dealt with through relief-of-pain. At home, neatly formed families of four are matched perfectly, taking age, gender, intellect, and activity level into account. Once the Old outlive their usefulness, they enjoy a celebratory "release." So too do fussy infants or unhealthy babies who might otherwise tax their mothers and fathers. Food is plentiful, everyone has a job he or she is well suited for, and the Elders think deeply on issues related to the community. What more could they—or any of us—want?
The answer to that question forms the crux of this haunting tale that explores a society perhaps not that far from our own. Lowry expertly teases out simple yet probing questions about free will and choice, about the inherent beauty of difference and the discomfort it causes, and about the wisdom we can and must glean from the past.
By the end of the unit the student will be able to:
1. Explain how the novel shifts from a utopian to a dystopian story.
2. Describe the role that our past plays in shaping our future.
3. Explain the relationship between freedom and security in Jonas's society.
4. Explain how this novel acts as an allegory for limiting or curbing choice, including expression, relationships, and sexuality.
5. Use examples to show how language is used to control behavior in Jonas's society and in our own.
6. Trace Jonas's evolution from child to man, including sexual development and his growing awareness of selflessness and responsibility.
7. Identify how and why uniformity is promoted in Jonas's society and in other societies; explain its effects.
8. Show how the author employs sensory language to highlight deficiencies in Jonas's community.


text: Greetings all -- I say urgent because I know it is late in the day, but I needed to have this working long ago and I'm annoyed that it is still failing. First the scenario: I am building some libraries on windows, both 32 and 64 bit. I am using MinGW as a mock linux environment as this software was developed on linux. 2 out of the 3 libraries configure and build fine, but the last library fails because of a missing command called pkg-config. I downloaded and installed the pkg-config binaries for 32 and 64 bit. I also downloaded and installed glib, another bit of software due to a dependency in the software. Note, when I say install, I mean I unzipped the binaries to their rightful places in the MinGW tree. I didn't start any processes running, just exported an environment variable so configure could find pkg-config. But configure is failing when it tries to run pkg-config. It dies saying it can't find a runtime, which I assume is a dll. It does find pkg-config, but can't execute it. I have tried everything short of diving into whatever docs I can find, which I don't have as the zip only came with binaries. So can someone please enlighten me on how this can be made to work? I have posted queries on the mingw users list but they haven't answered my latest queries. Thanks and happy hacking. (My hacking is haphazard...*smile*) --le __________ View the list's information and change your settings at http://www.freelists.org/list/programmingblind


text:
Adams Plans Tree Lighting; Holiday Village on ViewADAMS, Mass. — The town kicks off the holiday season on Sunday, Nov. 25, with the annual tree lighting on the Town Common from 2 to 5.
The Holiday Village, more than 200 pieces collected and installed by Dan Paciorek, is on view beginning Monday, Nov. 19, in the Town Hall Gallery weekdays from 8:30 to 4. The opening reception for the exhibit will be held during the tree lighting festivities on Sunday from 1 to 4.
This year's trees were donated by Eugene and Elizabeth Ziemba and Joseph and Theresa Alibozek. The ceremony will include activities and music.
Tags: holiday event,


text: I'd like to buy a really tough and durable black perfecto but I know nothing of leather jackets. My budget is 1200 Euros max. Any recommendations? It needs to be available in Europe. One thing to consider is that I am not very tall 1m72 and quite thin with straight shoulders. Thanks gents, much appreciated!


text:
Since I am in a fairly new relationship, who's beginning came from the most unexpected place - EVER, I'm curious as to how you met your significant other?
How did you meet your significant other?
Current Status: Published (4)
Thu Nov 15, 2012 11:02 AM
keyboard shortcuts: V vote up article J next comment K previous comment


text:
Am 13.01.2012 22:50, schrieb Josh Berkus: > Hackers, > > It occurs to me that I would find it quite personally useful if the > vacuumdb utility was multiprocess capable. > > For example, just today I needed to manually analyze a database with > over 500 tables, on a server with 24 cores. And I needed to know when > the analyze was done, because it was part of a downtime. I had to > resort to a python script. > > I'm picturing doing this in the simplest way possible: get the list of > tables and indexes, divide them by the number of processes, and give > each child process its own list. > > Any reason not to hack on this for 9.3? > Hello, I like the idea - but ... I would prefer to have an option that the user is able to tell on how much cores it should be shared. Something like --share-cores=N. Default is total core number of the machine but users should be able to say - ok - my machine has 24 cores but I want that vacuumdb just will use 12 of them. Especially on startups - you are able to find machines that aren't database-only machines. Often you find database and web server as single machine. Also you could have run more cluster on same machine for offering your business in different languages (one cluster per language). I already saw such a setup. There might be side businesses on the cores - so it should be possible that the users decides on how much cores he wants to share vacuumdb. Susanne -- Dipl. Inf. Susanne Ebrecht - 2ndQuadrant PostgreSQL Development, 24x7 Support, Training and Services www.2ndQuadrant.com
Next: From: Andres Freund Date: 2012-01-17 12:23:19 Subject: Re: 9.3 feature proposal: vacuumdb -j # Previous: From: Pavel Stehule Date: 2012-01-17 12:03:50 Subject: review: psql tab completion for GRANT role


text:
SBCL Threading Work, First Merge #
hacking, November 10th 2011
I just merged the first part of the IndieGoGo funded SBCL threading work. This entailed:
- GRAB-MUTEX now supports timeouts on all platforms.
- CONDITION-WAIT now supports timeouts.
- Killing lutexes, replacing them with userspace synchronization. This main affects non-Linux platforms. Performance implications are a mixed bag, depending on what you're doing. Some things perform an order of magnitude better, some things about the same, some things somewhat worse. The stability improvements on Darwin are well worth the costs, though and I will try to address the cases where performance suffers in due course.
There's more to come — stay tuned. ...and please report any regressions to SBCL bug-tracker on Launchpad or on the mailing lists.
EDIT: ...and just now I realized I left out the list of contributors I was supposed to include. Gah. Will add to later commit in the series. Sorry.


text:
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Snow Rolling Ford Raptor and Wester Wide-Out!
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