On May 9, 2026 the CRA announced the revocation of the Everlight Charitable Foundation, formerly known as the David Hofstedter Family Foundation (we will refer to it as Everlight throughout this article for simplicity). The CRA conducted four audits of Everlight between 1999 and 2025. The revocation documents provide clear and damning evidence backing the CRA’s decisions. The full revocation papers are available below, but a brief summary is provided as well.

Audit History

• Audit 1 period: 1 January 1999 to 31 December 1999
• Audit 2 period: 1 January 2002 to 31 December 2003
• Audit 3 period: 1 January 2008 to 31 December 2009
  • Compliance agreement signed: 15 December 2011
• Audit 4 period: 1 January 2019 to 31 December 2020
  • Notice of Intent to revoke: 2 April 2026

The latest audit (#4) “reviewed the implementation of the Compliance Agreement, as well as the Organization’s operations as a whole.”

About the Foundation

The David Hofstedter Family Foundation was “named for a wealthy Toronto real estate developer who was one of the organization’s founding directors. The entire board was replaced when the name was changed, according to the CRA.” It was established in 1987 and as of 2026 listed its ongoing programs as “selection of disbursements to qualified donees and the operation of Talmudic religion learning centres.” Prior to 2013 its ongoing programs were listed solely “selection of and disbursements to qualified donnees.”

We are in the process of conducting additional analyses, but in 2024 alone, Everlight:

• Gifted $155,444 to other qualified donees
• Received $3,070 from one other qualified donee (Fieldgate Cares Foundation)
• Sent $18,665,991 to Israel with no additional information provided about recipients
• Sent $11,799,156 to Dirshu International Inc in the United States. However, Dirshu International only reported a total of $2,445,400 of revenue from Everlight (David Hofstedter Family Foundation) on its 2024 tax return.
• Sent $1,574,828 to Kollel Dirshu UK Limited

The lack of transparency regarding funds sent to Israel has been well-documented.

In 2023, The David Hofstedter Family Foundation (Business No. 119229466 RR 0001) self-reported moving over CAD $17 million to “Israel”, with no intermediaries listed. This CAD $17 million+ was in addition to the CAD $26.6 million that The David Hofstedter Family Foundation listed as being earmarked for research grants and scholarships on line 4910 of its 2023 tax return (CRA 2024h). While not claimed as such, it is theoretically possible this money also went to Israel. A subsequent enquiry into publicly available tax returns (2019–2022) further confirmed that The David Hofstedter Family Foundation recently moved over CAD $90 million into the hands of international intermediaries for which no country codes were even listed.

Dr. Miles Howe, Tracking Financial Complicity in Israeli War Crimes and Genocide: Instances of Aiding and Abetting in the Canadian Charitable Sector

Dr. Howe also identified Everlight as one of the “big gifters” – a small group of Zionist oligarchs concentrated in Greater Toronto and Montreal. Specifically, Everlight is connected to the H&R Development Company, a Toronto real estate corporation. As part of the audit, the CRA found that Everlight had gifted funds to Beth Oloth Charitable Organization after it had already been revoked. Beth Oloth was named a “burner charity” by Howe and Sylvestre in 2022. Burner charities are “short-lived operation[s] with the apparent intent to move the maximum amount of cash out of Canada and into the international sphere, without regard for the legal parameters of the Income Tax Act, before ultimately being revoked.”

Just Peace Advocates had included Everlight in a complaint to the CRA.

The Audit Findings

The CRA stated that the “extent and nature of the non-compliance identified, some of which is repeated, are significant and systemic. The current audit revealed multiple serious and continued breaches of the [Income Tax] Act and common law.”

• Failed to devote its resources to charitable activities
• Failed to maintain adequate books and records
• Failed to file an information return as required
• Not constituted and operated exclusively for charitable purposes
• Gifted charitable resources to non-qualified donees
• Provided non-incidental private benefits approximating $43,000,000
• Failed to issue official donations receipts as required by law

Failed to devote its resources to charitable activities

• Dirshu: Provides financial incentives to beneficiaries from the organization or through third-party agents. The CRA was unable to confirm that the financial incentives provided aligned with the criteria and could not confirm the beneficiaries took the tests during the audit period as no dates provided on test score letters.
• Loans: Appears to have transferred charitable resources to non-qualified donees without necessary safeguards.
  • Westside Capital Corporation: No formal loan agreement but the Organization confirmed it was not for charitable purposes.
  • Bnei Torah Congregation: No formal agreement and appears that the Organization funded a non-qualified donee.
• Non-Qualified Donees on T1236: In 2019 and 2020, the Organization listed non-qualified donees on Form T1236 including Beth Medrash Govoha, Rabbinical Seminary of America, Vaad Mishmeres Mitzvos, Beth Oloth Charitable Organization, and Yeshiva Gedolah of Toronto.

Failed to maintain adequate books and records

• Activities failed to aligned with purposes in governing documents
• Governing documents are not as required by the Ontario Not-for-Profit Corporations Act, 2010
• No meeting minutes for Board of Directors and therefore no records regarding operations, decision making process, approval of disbursements, or discussions of the Organization’s foreign activities
• Loan agreements unavailable or non-existent and no documents to support the use of loan funds
• Incomplete general ledgers and trial balances, and various errors in bookkeeping
• Inadequate agreements/documents to support the funds transferred to agents and lack of evidence of ongoing communication with agents
• Poor internal controls re: safeguarding the Organization’s assets

Failed to file an information return as required

• Inaccurately reported employee compensation (reported compensation but indicated no employees at the time)
• Stated no foreign activities but the majority of their expenses were sent for activities outside of Canada
• Listed an amount for value of rent forgiven, but funds were never received and therefore shoul not have been included as part of the total eligible amount of all gifts for which the charity issued tax receipts (Line 4500)
• Additional failures to properly file their information return

Not constituted and operated exclusively for charitable purposes

• Registered to only make gifts to qualified donees but the Organization was “pursuing an unstated collateral non-charitable purpose of providing funds to non-qualified donees.”
• Specifically, administering Torah study programs and tests under the name “Dirshu”. “Dirshu appears to be an international organization that was founded by David Hofstedter and is headquartered in Israel.”

Provided non-incidental private benefits approximating $43,000,000

• Failed to demonstrate that it maintained direction and control over how its funds were used, and allowed non-qualified donees to use its resources with a private benefit.
• Provided a private benefit to Davpart Inc, a company owned by David Hofstedter (Director), by issuing a tax receipt for amounts that wee not received.

Failed to issue official donations receipts as required by law

Improper receipting by issuing official donation receipts:

• With incorrect information
• To wrong donor
• To a registered charity

The Result

Based on its Audit, and the Everlight’s inadequate response, the CRA issued its notice of intent to revoke the charity. The CRA expressly noted that the Organization was made aware of the requirements through the first three audits, yet they found issues of non-compliance and failure to implement corrective measures.