- Parties: The appellant was the Sigma Chi Canadian Foundation. The respondent was the Minister of National Revenue.

- Subject Matter: The appellant was registered as a charity, effective since 1992. Upon its registration, one of its stated objectives was to “assist deserving undergraduate, graduate, and other students attending or enrolled at institutions and systems of higher education in Canada who are in financial need to continue and complete their education at such institutions and systems.” The Minister of National Revenue issued a decision confirming her intention to revoke the appellant’s registration as a charity. The appellant appealed this decision under s. 172(3)(a.1) of the Income Tax Act, 1985.

- Ruling: The appeal court ruled in the respondent’s favour and dismissed the appeal. The appeal court saw no palpable and overriding error in the Minister’s findings that the appellant had provided private benefits to its members through its inhouse scholarships and that the appellant had provided funds to non-qualified donees by making loans to fraternity housing corporations, established to provide housing to members. The appeal court held that the appellant failed to establish a reasonable apprehension of bias or a deprivation of procedural fairness.

- Date: The hearing was set on Mar. 21, 2024. The court released its decision on Mar. 21, 2024.

- Venue: This was a federal case before the Federal Court of Appeal.

- Amount: The court fixed costs at $5,000, all-inclusive, in accordance with the parties’ agreement.