This article was originally published in Islamophobia Studies Journal (Pluto Journals): Available here (open access)

Publication date: 10 September 2025

Volume: 9, Issue: 1, Pages: 30-53

Burner Charities and Big Gifters—Tracking Illicit Activity Within in the Canada to Israel Charity Pipeline

Author(s): Miles Howe , Paul Sylvestre

Keywords: Israel/Palestine, philanthropic crime, state crime, Islamophobia, Zionism

Abstract

This article expands upon research surrounding transgressional charities within the Canada to Israel charitable subsector. Juxtaposed against credible accusations of anti-Muslim bias within the Canada Revenue Agency’s (CRA) charitable enforcement sector, this article suggests significant financial loss to the Canadian economy (potentially exceeding $1 billion CDN) as a result of transgressional, charitable, activity within the subsector. This paper further considers the leniency with which the CRA addresses instances of transgressional activity, both from a case-by-case and endemic standpoint. Aligning with the general critiques of philanthrocapitalism, regulatory enforcement within the Canadian charitable sector appears to target frontline operations, despite ample evidence of financial complicity with many of Canada’s most sizeable private foundations.

Main article text

INTRODUCTION

Accusations of an anti-Muslim bias within the Canada Revenue Agency’s (CRA) oversight of the Canadian charity sector (Emon and Hasan 2021; McSorley 2021) have not been alleviated, due in no small part to the CRA’s refusal to divulge its own risk analysis and profiling methodologies to the Office of the Taxpayer’s Ombudsperson (Office of the Taxpayer’s Ombudsperson 2023); this, despite a request for departmental cooperation from the pertinent bureaucratic lead, the Minister of Revenue. Lending peripheral credibility to charges of anti-Muslim bias, the Canadian Department of Finance’s most recently updated, cross-sectoral, National Inherent Risk Assessment (NIRA) framework (Department of Finance 2023)—which outlines security protocols for the Canadian financial sector (including the charitable sector)—was found by the CRA’s own in-house panel of specialists, the Advisory Committee on the Charitable Sector (ACCS), to be overly emphatic on ties between Muslim-identified actors and money laundering and terror-financing activities (ACCS 2023).

Broadening their critique beyond the obvious harms to the Canadian Muslim community caused by drawing a “presumptive nexus” between Muslim identity and terror and financial crime, the ACCS warned that the NIRA’s underlying (il)logic posed a security risk to the overall Canadian financial sector due to glaring gaps in oversight that the report had obliquely illuminated: Over-regulating against Muslim-identified actors and Muslim-identified recipients, based on biased data, did not render the Canadian financial sector more “safe.” Rather, the resultant blind spot in oversight (read: anyone not identified as Muslim) risked enabling—if not inviting—widespread harm to the Canadian financial sector (Ibid.).

A core question that emerges is: In a climate of potentially skewed baseline data, regulator obstinacy, and understaffed oversight (Professional Institute of the Public Service of Canada (PIPSC) 2019, 2024), what role does Islamophobic-informed enforcement play in facilitating potential criminality within the broader Canadian charitable sector? In other words, who might be taking advantage of the CRA’s self-imposed enforcement blind spot, and how? Beyond the exclusion of Muslim-identified organizations from meaningful participation in the Canadian philanthropic sector, at stake are donor confidence in the Canadian philanthropic sector itself, the potential of significant losses to public sector finances, and the potential of unidentified, illicit, activity taking place within the Canadian charitable sector.

Two recent case studies have focused on the potential of illicit activity associated with charities moving donations to one of Canada’s most significant, international, endpoints, Israel (Howe and Sylvestre 2025; Howe 2024a). Historically the first or second place international recipient of Canadian charity, in 2023 (the most up to date year of tax filing) Canadian charities moved over $271 million CDN directly into the hands of Israeli intermediaries (CRA 2024a), with another roughly estimated $100 million CDN heading to Israeli qualified donees, such as universities (Blumberg 2024).

Despite an understandable hesitancy to critically engage with the financial activities of a historically maligned community, specifically along financial tropes (see Berkowitz 1996), these two case studies suggest an unknown, yet significant, degree of illicit activity within the Canada to Israel philanthropic pipeline. Importantly, pointing the way toward a crime of the powerful analysis, and nodding to the possibility of a Canadian, Khalidian, Zionist metropolitan (1971), both case studies make note of the outsized, financial, participation of private foundations within the pipeline, linked to some of the most significant oligarchic fortunes in Canada.

It is the aim of the following investigation to forward the work undertaken in the above case studies by methodologically documenting recent-historical (2018–24) illicit activity within the Canada to Israel philanthropic pipeline, as determined and disclosed by the CRA itself. With an eye toward developing typologies that might facilitate future understanding of illicit activity within the broader Canadian charitable sector, and toward gaining a deeper understanding of the role that philanthropic foundations play in the furtherance of such illicit activities, CRA investigative efforts will be methodologically complemented by tax return data acquired under the Access to Information Act.

Guided by this aim, this article moves forward in five parts. In the first section, a brief consideration of applicable theoretical groundings is considered. In the second section, the historic and ongoing role of philanthropic foundations in furthering foreign policy objectives, along with Zionist expansionism, is considered. The third section recaps the findings of the three pertinent case studies, toward bringing forth the potential of typological characteristics. The fourth section presents the methodology guiding this investigation, while the fifth section considers the findings.

Theoretical grounding

Crimes of the powerful analysis

In highlighting the outsized participation of Canadian private foundations within the potentially illicit movement of finance—in the form of charitable donations—from Canada to Israel, two guiding insights, gleaned from crimes of the powerful research, inform the interrelationships between crime and capitalism. First, criminal activity perpetrated by wealthy elites, corporations, and state actors dwarfs the crimes of the comparatively powerless in terms of their prevalence and the social harms they engender (Barak 2015). Second, perpetrators of crimes of the powerful receive markedly gentler social sanctions than law-breaking perpetrated by the comparatively powerless. This, however, has less to do with differences in either prevalence or harms caused by either class of offender, and more to do with the relative social power and status of elite offenders (Bittle et al. 2018; Sutherland 1983).

It follows that the enactment of law—its application, interpretation, and codification—is one in which the interests of the wealthy and powerful tend to dominate (Pearce and Tombs 2019). As such, corporate deregulation and the chronic underenforcement of white collar and corporate crime (Bittle and Hebert 2019), the protection of property and profits over human health and lives (Benz 2019), and the fact that an ever expanding array of demonstrably harmful corporate and state practices escape formal prohibition under law, are then a vantage from which to interrogate the stark power asymmetries structuring liberal capitalist societies (Pearce 1976). Indeed, a point forcefully made by Frank Pearce (Ibid.) is that one cannot hope to understand crime by studying it in isolation from the social relationships that comprise the capitalist world system. Charity, although frequently presented as a salve to be altruistically applied against the inequalities brought about by the capitalist world system, is by no means immune to the influence of unequally applied, interpreted, and codified legal frameworks.

The rise of foundation philanthropy

The past two decades have borne witness to an unprecedented growth in foundation philanthropy tied to corporate fortunes and wealthy elites. Philanthropic activity comprises upwards of 10 percent of total GDP in most G7 countries, and charitable assets worldwide topped $2.5 trillion USD as of 2022. In Canada, recent figures suggest that the charitable and non-profit sector represents 8.3 percent of Canadian GDP (approx. $189 billion CDN in assets) and employs over 10 percent of the population (Imagine Canada 2022). As with most “Western” states, small frontline charities, legally registered as charitable organizations under the Income Tax Act, still make up the numeric bulk of charities in Canada. Private foundations, frequently directly linked to corporate wealth and dynastic, family, fortunes have grown steadily since the early 2000s, comprising around 6,300 organizations out of Canada’s more than 86,000 registered charities. Collectively, private foundations control an outsized portion of total charitable assets in Canada; despite their numeric scarcity, assets under private foundation control are valued at between $116–120 billion CDN (Blumberg 2022; Imagine Canada 2022). Law, as expressed most applicably by the Canadian Income Tax Act, has arguably worked toward facilitating and encouraging this ever-increasing disparity in class-based ownership over charitable assets.

Unlike Canadian charitable organizations, which are legally obligated to spend most of their yearly revenues on self-directed programming and operations, foundations in most jurisdictions are only required to disburse a minuscule fraction of their tax-sheltered funds (CRA 2002). The overtly stated hypothesis underwriting the facilitation of this tax-haven situation is that the large pools of assets controlled by philanthropic foundations are more enduringly productive to the state when they are tax sheltered and then subsequently invested in financial markets, with the untaxed capital gains or interest theoretically recirculated into bankrolling the provision of social services via the operations of frontline charities.

The presumption, here, is that the corporate directors at the helm of said philanthropic foundations will be altruistically guided to reinvest such profits into the charitable sector, and not, say, simply maximize profits by any means necessary. This is the paradox of philanthropy within liberal democracy, as outlined by Sievers (2010), with the Canadian state, under the parameters of the Income Tax Act, playing a faciliatory role in growing the asset base of philanthropic foundations: Whether public and private, under the Income Tax Act foundations operate as tax havens and must only disburse of 5 percent of their pooled assets per year, when in excess of $1 million CDN (CRA 2023a).

Rather than an ameliorative response to the harms wrought by the neoliberal-driven abandonment of the welfare state project, crafting a charity sector around maximizing the possibilities for enrichment of the ultra-wealthy, represents a symptomatic continuation of this very abandonment. Charitable funding streams undermine the transformational agendas of radical social movements (King and Osayande 2017), depoliticize socio-economic inequality by individualizing social problems as personal failing best addressed through entrepreneurialism and market solutions (Amarante 2018; Eikenberry and Mirabella 2018), usurp democratic governance in favor of plutocratic rule (Reich 2018), extend privatization and corporate profiteering further into our dwindling collection of public services (Saltman 2023), and, yes, selectively patch holes in the shredded social safety net left in the wake of organized state abandonment.

When one considers the well-documented recalibration of the philanthropic sector into a comprehensive financial storehouse and enrichment engine for the ultra-rich, calls for legal reforms and interventions into episodes of philanthropic crime butt up against facile depictions of charity as an unassailable good, which naively construct the legal system as an objective agent, uninvolved in the very perpetuation of the rampant inequality that defines philanthrocapitalism. This is the fulcrum where critical criminology-derived insights speak to philanthropic studies. Offering perhaps the most coherent critical criminological engagement with foundation philanthropy, Linsey McGoey and colleagues (2018, 32) argue that philanthrocapitalism must be viewed as a crime of the powerful in that the overarching, “for the good,” narratives that enduringly surround charity “serves as a powerful defensive shield for the vagaries of capitalism.” For these authors, the narrative that equates foundation philanthropy with more ancient meanings of gifting, such as reciprocity (see Godbout and Caillé 2000), works to sanitize and obscure the social harms of the processes of accumulation by dispossession upon which foundation philanthropy is predicated.

Philanthropy, international relations, and foreign policy

Significant historical inquiries have charted foundation philanthropy’s clutch role in exporting (specifically Cold War era American and British) foreign policy, as well as its overall function as a plausibly deniable tool for the transfer of finances on behalf of bureaucratic and intelligence power structures (see Berman 1983; Stonor Saunders 1999). While such analyses have focus upon the complicity of industrial titan-associated private foundations in the waging of a Cold War, cultural and otherwise, against the former USSR, more recent investigations have highlighted the financial complicity of American international humanitarian aid bodies, such as the United States Agency for International Development and the National Endowment for Democracy, in successful and botched coup attempts the world over (see Kaiser et al. 2023; Klarenberg 2025; Ramazani 2025). Any analysis concerning the operations of private foundations, one might argue, should not limit itself to the possibility of criminality motivated by self-enrichment; these pools of privately held wealth have a rich and ongoing history of weaponization in the advancement of “home state” foreign policy.

Speaking directly to the ongoing, colonial, purposes to which Zionist-supportive charities have classically devoted themselves, the development of a philanthropic pipeline sourced to a Zionist establishment located within the territorial confines of a “gentile sponsor,” with Israel as its endpoint (Khalidi 1971), has been vital to the ongoing colonization of Palestine. The rallying of charitable donations in this regard predates, by decades, the 1948 creation of the State of Israel itself (see Simpson 1971; Berkowitz 1996, 1997). The vitality of this pipeline to Israeli state policy must not be underestimated; Keren Kayemeth Leisrael and Keren Hayesod, most notably, maintain satellite fundraising offices around the world, in the form of the Jewish National Fund and the United Israel Appeal, respectively, and have cumulatively handled billions of dollars in Israeli state-bound revenue. Entrenched by law within the Israeli bureaucratic framework (see State of Israel 1953, 1956), these organizations have been tasked with ensuring and solidifying Israel’s position as a Jewish-majority state; actions in this regard have involved using sponsor-derived funding toward territorial expansion (and subsequent displacement of indigenous populations to Palestine), red-lining the sale of lands to Jewish-only purchasers, and the undermining of all challenges (legal and otherwise) to the Zionist expansionist project (Ibid.; see also Simpson 1971).

Canada, to be sure, has never been Zionism’s “top tier” gentile sponsor. But as the following section makes clear via recourse to two case studies, a significant percentage of the yearly finances heading through the Canada to Israel philanthropic pipeline bears scant resemblance to fulfilling formalized definitions of “charitable purpose” under common law. Rather, with millions of dollars per year earmarked toward supporting Israel’s illegal occupation and the Israeli military, the Canadian charitable sector has ostensibly given itself over to fulfilling Israeli state policy, while roundly ignoring Canada’s own public policy specifically concerning the illegality of the Israeli settlements and the applicability of customary international law (Global Affairs, 2024). Troublingly, particularly when compared against allegations of over-enforcement against Muslim-identified charities, the Canada Revenue Agency appears disinterested in ensuring that even bare modicums of reporting requirements concerning Israel-bound philanthropy are adhered to.

TRANSGRESSIONAL TYPOLOGIES

The burner charity

In their investigation concerning the activities of three, synchronously linked, Canadian charitable organizations, Howe and Sylvestre (2022) introduced the concept of a “burner charity,” a short-lived operation wih 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. The research determined that tens of millions of dollars CDN, sourced to private foundations managed and financially linked to corporate and dynastic fortunes, had systematically left Canada for Israel via a string of directorially connected charitable organizations. Utilizing decades worth of charitable tax returns, the researchers charted the ebbs and flows of philanthropic-associated donations, moving en masse from one burner charity to the next, with shifts in funding source appearing to directly overlap with attempts at regulatory enforcement on the part of the CRA.

Key typological trademarks of a burner charity included:

• Legally registered as a frontline, charitable organization.
• No public-facing profile (no website, social media footprint, or physical office).
• Initial status registration followed by a period of multi-year, transactional, dormancy.
• A period of activation, defined by total received revenue surpassing $1 million CDN, followed by a multi-year period of escalating receipt, and dispersal, of revenue.
• Reporting requirements concerning international intermediaries (in this case associated with Israel) overlooked/ignored.
• Revenue is significantly sourced from private foundations (>25 percent).
• Attempts at CRA regulatory enforcement lag years behind the activation period.
• Stalling tactics (legal obfuscation, etc.) may be introduced, allowing the burner charity to operate for several more years after the first CRA attempts at contact/enforcement.
• Regulatory enforcement limited to charitable status revocation of implicated charitable organization with no criminal charges laid.
• Implicated public and private foundations (i.e., discernible sources of revenue) escape identification within CRA audits. No enforcement measures applied to implicated foundations.

Howe and Sylvestre’s overall conclusion was that philanthropic foundations, in this case exemplified by private foundations linked to real estate fortunes concentrated within the Greater Toronto Area, appeared to have made coordinated usage of the three burner charities under investigation. The effect, taken holistically, was of tens of millions of dollars in philanthropic donations having claimed to have moved into Israel, with no discernible purpose or charitable activity attached.

The war crimes conduit

The second case study (Howe 2024a) focused on the activities of the Mizrachi Organization of Canada, which overtly announced itself as a financial conduit for Israeli intermediaries complicit in illegal settlement and/or military supportive activities (see ICJ 2024; UN 1980a, 1980b, 2016, 2023a, 2023b, 2024). In contrast to the burner charity model, Mizrachi Canada, as of fiscal year 2022, listed dozens of Israeli intermediaries. The activities of many of Mizrachi Canada’s Israeli intermediaries (for whom it is legally responsible) ran in contravention of Canadian public policy, along with both international and Canadian legal frameworks pertinent to the aiding and abetting of war criminality, which in this case included settlement expansion, Palestinian dispossession, and financial and material support for the Israeli military (see, specifically Government of Canada 2000 (Crimes Against Humanity and War Crimes Act 2000); Government of Canada 1985b (Geneva Conventions Act 1985; Interpretations Act 1985).

Central to Mizrachi Canada’s operations, as of writing, continues to be its ongoing relationship with the Israeli website, jgive.com, via which it streamlines donations from would-be Canadian donors to Israeli charities: Canadian donors wishing to donate to an Israeli charity listed on the jgive.com website are provided with a tax receipt (valued at upwards of 50 percent of the donated principle) by Mizrachi Canada. As such, Mizrachi Canada provides an otherwise inaccessible financial incentive for Canadian Zionists wishing to advance Israeli expansionism, as the Israeli charities to whom the Canadian donations are funneled have no means, on their own, of issuing Canadian tax receipts.

This service itself represents a classic “conduit” relationship, whereby a Canadian charity simply provides a fundraising service for another organization, over which it maintains no direction and control; it is not permitted under the Income Tax Act (CRA 202, Howe 2024a). Importantly, the case study determined that Mizrachi Canada was not the only Canadian charitable organization operating as a “conduit” for the Israeli charitable sector; the actively registered charity, Canada Charity Partners, as of writing provides streamlined tax receipting services to Canadians wishing to make donations to Israeli charities (many of which are engaged in settlement-based war criminality) (Ibid.).

Key typological characteristics of a war crimes conduit:

• Public-facing profile announces affiliation with a discernibly non-charitable purpose (in this case, Zionist expansionism).
• Issues charitable tax credits for donations earmarked for international intermediaries, on behalf of Canadian donors.
• Properly lists international intermediaries.
• Foundation-derived donations remain an important source of revenue but in and of themselves are peripheral to the active aiding and abetting of war criminality.
• Canada Revenue Agency, for its part, appears to ignore both international and domestic law requirements concerning financial complicity in the aiding and abetting of war criminality.

Case study considerations

Clearly, there are marked differences between the two typologies presented for consideration. On the one hand, within the burner charity typology, endemic non-compliance in reporting requirements obscures Israeli endpoints. As a result, ascribing discernible, foreign policy-related, objectives to the movement of donations into Israel becomes a conjectural exercise. On the other hand, this lack of baseline reporting, year in year out, raises troubling questions surrounding regulator capacity/complicity.

Within the war crimes conduit typology, the illicit component of the philanthropic crime very much lies within the self-stated purpose claimed by the Israeli intermediaries in receipt of Canadian donations. In this case, the internationally illegal activities of Zionist-oriented Israeli intermediaries contravenes applicable Canadian legal frameworks, along with Canadian public policy on the illegality of the Israeli occupation, post-1967.

The similarity within both typologies is the financial participation of what appears to be a coordinated and cooperative network of philanthropic foundations, many of which represent the financial operations and interests of Canadian corporate and dynastic fortunes. In both typologies, these foundations have in all cases escaped the investigational priorities of CRA audit investigators, along with many of the operational-based regulatory parameters of the Income Tax Act.

In the following section, a methodology is introduced with an eye towards moving beyond the case studies, towards charting further instances of philanthropic crime, specifically within the Canada to Israel philanthropic pipeline. This methodology aims to provide a more holistic accounting of possible philanthropic crime and philanthropic foundation participation, both within and beyond this particular subsector.

Methodology

Both case studies provide a means toward investigating both financial origins and exit points, along with the potential of regulator bias, within the Canada to Israel philanthropic pipeline. The following section explains the methodology applied toward capturing a more holistic overview of illicit activity within the pipeline itself, which at once aims to measure the participation of philanthropic foundations in said illicit activity, along with documenting the regulatory steps—or lack thereof—taken by the CRA once illicit activity had been identified. Toward these aims, the following methodological process was undertaken:

Firstly, an Access to Information (ATI) request was sent to the CRA for a list of all revoked Canadian charities, due to a failed audit, who had listed at least one Israeli intermediary in the “Schedule 2—Overseas Activity” section of their yearly tax returns, between 2018–24 (CRA 2024a). The 2018–24 timeframe was undesirable but necessary, as CRA Notices of Intention to Revoke (NITR) are only kept by the CRA for a period of six years, as per the department’s Records Retention and Disposition Procedures, after which the regulator claims they are destroyed (CRA 2024b). NITRs are only generated and made publicly available in cases where a charity has its charitable status removed due to a failed audit; they contain the CRA’s investigatory findings, insights into investigatory methodologies, justifications for status revocation, and correspondences between the charity and the regulator.

With this first list in hand, a financial exclusion point was next set. Given that the monetary scope of the Canada to Israel charitable subsector is valued at anywhere between $270–360+ million CDN per year (see Blumberg 2022), it was determined that only charities that had received, minimum, $500,000 CDN per year in donations during at least two years of operation would be included for further investigation. Charities operating below this threshold were determined to be financially irrelevant to the activities of the overall pipeline. Seven revoked charities passed this exclusion point.

A secondary round of ATI requests was next sent to the CRA, aimed at capturing the operational histories of these seven revoked charities. Requests included queries to the CRA for a) data concerning donations that had been received by the revoked charities from other Canadian charities, by name and dollar amount, b) data concerning all overseas intermediaries, by name and dollar amount, c) all changes in boards of directors, and d) total revenue per year, between 2000–24. As per Howe and Sylvestre (2022), a multi-decade timeframe was requested toward identifying the possibility of inter-charity cooperation in operations. Requests were also sent to the CRA for the NITR packages for each of the seven revoked charities. Taken together, the intent was to draw out the operational intricacies of the revoked charities over an extended linear timeframe, while contrasting this data against the audit findings of the CRA, which typically only focus on a limited timeframe (generally only one or two fiscal years).

Section 1 of the “Findings” section presents, first, bullet point synopses of the operations of these seven revoked Canadian charities, legally registered as: Colel Chabad Lubavitch Foundation of Israel, Kupas Hachesed Meoroth, Chasdei Levy Yitzcok, Gates of Mercy, Beth Oloth Charitable Organization, Ne’eman Foundation Canada, and Jewish National Fund of Canada.

Section 2 of the “Findings” graphically presents donations received by the seven revoked charities from other Canadian charities. The intent, here, was to determine the financial participation of Canadian charities—specifically private foundations—into the activities of the revoked charities themselves. In building the graphic in Section 2, an internet search was undertaken for each Canadian charity that had exceeded the below-described financial exclusion point in their donations to the revoked charities. Where possible, the source of wealth to which the donor charities were aligned was identified, as were overlaps in corporate and charitable boards of directors. Where meaningful overlaps were found to exist, aggregated entities—in certain cases comprising numerous charities with overlapping directorial linkages—were created. Donations originating from these aggregates were tallied and counted as a singularly sourced donation.

For the sake of relevancy, a second financial exclusion point was set: Any single charity or aggregated entity that had moved less than $1 million CDN total to any one or combination of any of the seven revoked charities was excluded from graphic representation.

Findings (i)—revoked charity synopses

Colel chabad lubavitch foundation of israel

• Registration: 1993 (Colel Chabad Lubavitch Foundation of Israel v Canada (National Revenue) 2022. FCA 108).
• Activation point: Fiscal year 2000 (CRA 2016)
• Website/Social Media:
  • No
• Initial Audit: Undertaken in 2006 for the fiscal period of 2003–4.
• Findings/Actions Taken:
  • Compliance Agreement with the CRA in 2006.
  • Under the Agreement, Colel Chabad promised to increase direction and control over the operations of Israeli intermediaries and improve deficiencies identified in record-keeping and minute-taking.
  • Specific deficiencies were identified by the CRA, pertaining to lack of documentation in issuance of scholarships to Israeli recipients (Ibid.).
• Subsequent Audit: Undertaken in 2013 for the fiscal period of 2008–9.
• Findings/Actions Taken:
  • CRA investigation suggested Colel Chabad had been participating in a “donation scheme.”
  • CRA claimed that donation receipts were sold to donors for 10–20 percent of the receipts’ gross value. 80–90 percent of the principal would be “washed” and returned to the investor, who was issued a tax receipt worth anywhere from 35–50+ percent of the principal.
  • In at least one case, a Belizean company received a full donated amount, subsequently returned 80–90 percent of the receipts’ gross value to the implicated donor (see Brean 2011; Colel Chabad Lubavitch Foundation of Israel v Canada 2022, at para 14).
  • Colel Chabad’s president, Abraham Neuwirth, claimed ignorance of the scheme.
  • Colel Chabad’s secretary, Zalman Zirkind, along with his brothers, were involved in a wider, international, narco-trafficking/money laundering scheme, in which the charity played an uncertain role (see Mandel 2019).
  • In 2021, Zalman was sentenced to 84 months’ imprisonment by a United States District Court for conspiracy to commit money laundering, on charges that did not refer to his secretarial role in Colel Chabad (US v Bomba).
• Follow-up:
  • A 2016 CRA investigation determined the reimbursement scam totaled a minimum $2.67 million CDN (CRA 2016).
  • Colel Chabad would claim they had been the victim of a scam perpetrated by an “outside party” and would lay blame on their sole Israeli intermediary, Moshe Deutsch (Ibid.).
  • Deutsch would claim no knowledge of the scheme. Despite accusations against him, he would remain Colel Chabad’s Israeli agent.
  • CRA further determined a rampant failure to demonstrate direction and control of dispersal of funds by the Israeli intermediary, along with claims of falsified board meeting minutes. (Ibid.)
• Total Years “Active”: 16
• Total Revenue Claimed:
  • (2000–15) $20,103,928 CDN (CRA 2024c)
• Total Revenue Claimed from Canadian Charities:
  • (2000–15) $1,944,756 CDN (9.6 percent) (CRA 2024d)
• Conclusion: Colel Chabad ceased filing tax returns after the fiscal year 2015.
  • In 2022, Federal Court of Appeal upheld Minister of Revenue’s decision to revoked Colel Chabad’s charitable status (Colel Chabad Lubavitch Foundation of Israel v Canada (National Revenue) 2022).

Kupas hachesed meoroth (khm)

• Registration: 2007
• Activation Point: Fiscal year 2008
• Website/Social Media:
  • No
• Initial Audit: Undertaken in 2018 for fiscal period 2013–16 (CRA 2024e).
• Findings/Actions Taken:
  • CRA informed KHM that it was unable to verify the validity of donations, totaling over $32 million CDN, between 2014–15. Further noted that it was unable to verify any reported disbursements of funds to KHM’s claimed Israeli intermediary (Ibid.).
  • Further investigation into KHM’s “wire transfer information” determined that only $100,862 CDN had been sent to Israel between 2014–16.
  • As noted by the CRA: “the majority of the funds spent on foreign activities were actually given to individuals residing in Canada and cashed at Canadian bank accounts” (Ibid.).
  • Funds totaled over $48 million CDN between 2013–16 had apparently been delivered to an unknown number of Canadian and American recipients via cashed cheques, typically written out to individuals identified by first initial and last name only.
  • CRA concluded that: “it does not appear that any charitable activity occurred, whether within or outside of Canada” and that “it appears the Organization is simply gifting funds to individuals and conferring an unacceptable private benefit” (Ibid.).
• Total Years “Active”: 13
• Total Revenue Claimed:
  • (2008–20 (No returns available 2017–19)) $145,482,898 CDN (CRA 2024f)
• Total Revenue Claimed from Canadian Charities:
  • $40,868,235 CDN (28 percent) (CRA 2024g)
• Conclusion: No legal challenge to CRA’s findings was issued. KHM’s charitable status was revoked in 2022.

Chasdei levy yitzcok (cly)

• Registration: 2008
• Activation Point: Fiscal year 2009
• Website/Social Media:
  • No
• Initial Audit: Undertaken in 2018 for the fiscal period 2015–16 (CRA 2024h)
• Findings/Actions Taken:
  • CRA audit determined that Montreal-based Chasdei Levy Yitzcok (CLY) had demonstrated widespread failure in issuing proper donation receipts and had failed to carry on its own charitable activity.
  • The CRA would note no documentation to “confirm any interaction” between the charity and its Israeli agents, or that the agents “performed any work” for the charity (Ibid.).
  • The CRA determined that CLY had issued over 600 cheques, totaling over $2.7 million CDN, to several “foreign residents,” during the fiscal year of 2016 (Ibid.). These foreign residents had cashed their cheques at an unnamed business that offered “cheque-cashing services.”
  • The CRA found that identification was frequently not presented at the time of cheque-cashing and that, in certain instances, representatives of CLY were cashing cheques they had written to themselves (Ibid.).
  • The CRA determined that none of the foreign residents named by CLY had legally entered Canada within a five-year time span prior to the audit (Ibid.).
• Total Years “Active”: 13
• Total Revenue Claimed:
  • (2009–21) $68,066,435 CDN (CRA 2024i)
• Total Revenue Claimed from Canadian Charities:
  • (2009–21) $30,816,950 CDN (45 percent) (CRA 2024j)
• Conclusion: No legal challenge to CRA’s findings was issued. CLY’s charitable status revoked in 2023.

Gates of mercy

• Registration: 1991
• Activation Point: Fiscal year 2005
• Website/Social Media:
  • No
• Initial Audit: Undertaken in 2012 for the fiscal period 2008–10 (CRA 2018a)
• Findings/Actions Taken:
  • The CRA’s audit found that Gates of Mercy had “failed to retain direction and control over the use of its funds,” had failed to keep “adequate books and records,” had “issued receipts not in accordance with the [Income Tax] Act,” had failed to “file an information return in prescribed format” and had no means to demonstrate or ensure these uncontrolled funds were being utilized for its own charitable activities if/once they reached Israel (Ibid.).
  • Gates of Mercy entered into a Compliance Agreement with the CRA in 2012; corrective measures were introduced with a promise to comply (Ibid.).
• Subsequent Audit: 2016 audit for fiscal period 2010–13.
• Findings/Actions Taken:
  • Subsequent audit determined that compliance activities had not taken place.
  • Overlaps in personnel, along with questionable financial linkages, with Beth Oloth Charitable Organization.
  • Extended period of legal obfuscation by Gates of Mercy after attempted communication by CRA in 2016 (Ibid.).
• Total Years “Active”: 14
• Total Revenue Claimed:
  • (2005–18) $122,692,642 CDN (CRA 2024k)
• Total Revenue Claimed from Canadian Charities:
  • (2005–18) $62,878,563 CDN (51 percent) (CRA 2024l)
• Conclusion: No legal challenge to CRA’s findings was issued. Gates of Mercy’s charitable status was revoked in 2019.

The beth oloth charitable organization

• Registration: 1981
• Activation Point: Fiscal year 2012
• Website/Social Media:
  • No
• Initial Audit: Undertaken in 2016 for fiscal period 2011–14 (CRA 2018b)
• Findings/Actions Taken:
  • CRA audit determined that Beth Oloth was non-compliant with the Income Tax Act on a variety of levels, including: “Failure to be constituted for exclusively charitable purposes,” and a “failure to devote resources to charitable activities carried on by the organization itself” with a specific emphasis on a “lack of direction and control over the use of resources/resourcing non-qualified donees.”
  • The CRA evinced further concern that Beth Oloth was depositing cheques made out to Shmuel Reidel, sole active director at Gates of Mercy.
  • Representatives from Beth Oloth claimed Reidel no longer held a formal association with the charity and maintained an “advisory role” only.
  • The cross-depositing of cheques between the two charities, however, suggested to the CRA the existence of an undisclosed relationship/arrangement between the two organizations (Ibid.).
  • The CRA’s audit into Beth Oloth’s activities revealed a massive list of international intermediaries.
  • In 2012, Beth Oloth claimed that it had moved over $8 million CDN to 713 intermediaries. In 2013, this increased to nearly $24 million CDN to 1,784 intermediaries, and in 2014 over $31 million CDN was moved to 2,274 intermediaries (Ibid.).
  • The CRA considered this impossible, due to the sheer scope of intermediaries being claimed.
  • Extended period of legal obfuscation by Beth Oloth after attempted communication by CRA in 2016.
• Total Years “Active”: 6
• Total Revenue Claimed:
  • (2012–17) $220,513,005 CDN (CRA 2024m)
• Total Revenue Claimed from Canadian Charities:
  • (2012–17) $110,808,337 CDN (50 percent) (CRA 2020)
• Conclusion: No legal challenge to CRA’s findings was issued. Beth Oloth’s charitable status was revoked in 2019.

Ne’eman foundation canada

• Registration: 2011
• Activation Point: Fiscal year 2016
• Website/Social Media:
  • Yes (since deleted)
• Initial Audit: Undertaken in 2021 for the fiscal period 2016–17 (CRA 2024n)
• Findings/Actions Taken:
  • As with Mizrachi Organization of Canada, Ne’eman Canada acted as a Canadian clearing house for the Israeli charitable sector, listing links to hundreds of Israeli charities on its website, while promising Canadian charitable tax receipts to prospective donors.
  • Ne’eman Canada did list hundreds of Israeli intermediaries.
  • The CRA cited Ne’eman Canada for several regulatory infractions, concerning bookkeeping, and a lack of direction and control over its intermediaries (Ibid.).
  • Notably, the CRA would work through Ne’eman Canada’s listed Israeli intermediaries and would highlight the non-charitable purpose of several of these.
  • The CRA highlighted the activities of several Israeli intermediaries engaged in Palestinian dispossessions and financial assistance to the Israeli military as a partial cause for Ne’eman Canada’s status revocation (Ibid.)
  • No mention was made by CRA of infractions of Canadian public policy or war criminality.
• Total Years “Active”: 8
• Total Revenue Claimed: (2016–23) $52,219,861 CDN (Charity Data 2024a)
• Total Revenue Claimed from Canadian Charities: (2016–23) $40,895,934 CDN (78 percent) (Ibid.)
• Conclusion: No legal challenge to CRA’s findings was issued. Ne’eman Canada’s charitable status was revoked in 2024.

Jewish national fund of canada inc. (jnf canada)

• Registration: 1967
• Activation Point: N/A
• Website/Social Media:
• Yes
• Initial Audit: 1977 ¹ (CRA 2024o)
• Findings/Actions Taken:
  • Registered as a charity in 1967, JNF Canada (initially registered as Jewish National Fund of Canada—Keren Kayemeth Leisrael) was, infamously, responsible for moving charitable donations into the construction of “Canada Park,” built atop the razed Palestinian villages of Imwas, Yalu, and Bayt Nuba (see CBC 1991).
  • JNF Canada’s proximity to political power was/is significant. Numerous federal ministers, including former Prime Minister Stephen Harper, have attended yearly JNF Canada events, including the annual “Negev Dinner” fundraiser.
  • JNF Canada was historically pampered by various Canadian bureaucracies: media lines, produced in 2010, aimed to assist federal government personnel toward downplaying the charity’s well-documented, non-charitable, activities in Israel.
  • Israeli organization Keren Kayemeth Leisrael (KKL) was historically JNF Canada’s central recipient. Between 2018–22, JNF Canada self-declared having sent over $26 million CDN to Israel in charitable donations; over $23 million CDN of these funds were directed to KKL (Charity Data 2024b).
  • As per the 2016 audit, the CRA’s revocation focused upon the lack of direction and control that JNF Canada displayed over the activities of KKL, as well as the non-charitable purposes to which KKL devoted itself (CRA 2024o).
  • The CRA took specific issue with the lack of direction and control over the non-charitable activities of “indigent workers,” ostensibly brought out of poverty by JNF Canada donations administered to them by the KKL (Ibid.).
  • As far as the CRA could determine, JNF Canada was simply funding KKL’s infrastructural development projects by paying Israeli workers who, according to the CRA’s findings, were not experiencing poverty or in financial need (Ibid.).
  • The CRA also raised an issue with the activities of the KKL as non-charitable. Although the CRA noted that JNF Canada had, since 2019, a Memorandum of Understanding in place with KKL, the Israeli organization had, since at least 2017, been actively involved in deceit of its donors, and had engaged in the surreptitious purchase of lands within the West Bank (Peace Now 2022).
• Total Years “Active”: N/A
• Total Revenue Claimed: (2003–22) $233,858,829 CDN (?) (Charity Data 2024b)
• Total Revenue Claimed from Canadian Charities: Claimed—(2003–22) $0.00 CDN (Charity Data 2024b)/Based on ATI request—(2000–23) $102,173,134 CDN (?) ² (CRA 2024p)
• Conclusion: JNF Canada appealed CRA’s decision to revoke its charitable status.
  • On November 8, 2024, the Federal Court cited jurisdictional issues and dismissed JNF Canada’s appeal.
  • JNF Canada has insisted it will continue to challenge CRA’s decision at the Federal Court of Appeal. As of writing, charitable status is currently revoked.

FINDINGS (II)—CHARITY TO CHARITY DONATIONS

Graphic 1 presents the sources of all donations ($1 million + CDN) received by the revoked charities, as received from other Canadian charities. In reading the graphic, readers should note the usage of several headings: “Type of Fortune” refers, where applicable, to the economic activity from which the donating charities derive their assets. “Location” refers to the physical location of the source activity associated with the donating charities (GTA—Greater Toronto Area, MTL—Montreal). “Source of Capital/Charity Type” refers, first, to the legal name of the source of corporate capital associated with the donating charities, which is followed by the legal classification for each donating charity (private foundation, public foundation, or charitable organization).

Graphic 1.

Inter-charity flows of donations to revoked charities (due to a failed audit) with claimed Israeli intermediaries (2018–2024)

Considerations

The findings raise various points for consideration; approaching the activities of each revoked charity outlined in Findings (I), on a case-by-case basis, reveals both similarities and differences to the originally presented set of typological characteristics.

Colel Chabad appears to fit all the characteristics of a burner charity typology, excepting the limited financial participation of other Canadian charities (under 10 percent of all revenue was sourced back to other Canadian charities). Rather than discrediting Colel Chabad from the burner typology, we argue that the lack of intra-charity donation movement is related to the fundaments of Colel Chabad’s alleged donor scheme, which according to the CRA involved selling official donation receipts to prospective donors for 10–20 percent of the receipts’ gross value, offering a tax credit for the full donated amount, and circuitously returning 80–90 percent of the donation’s gross value back to the donor. Donations made between charities, importantly, do not generate an official tax receipt, as Canadian charities already operate as tax-free operations. This means that no financial gain would be netted by other Canadian charities donating to Colel Chabad’s alleged scheme, which would be of financial value to individual donors only. As such, minimal inter-charity participation is, arguably, to be expected.

Both Kupas Hachesed Meoroth (KHM) and Chasdei Levy Yitzcok (CLY) appear to operate as classic burner charity typologies. In both cases, however, there was no significant dormancy period prior to activation. Rather, both charities were receiving millions of dollars in charitable donations within one year of registration. Although extended dormancy appeared as a key characteristic of the burner charities identified within Howe and Sylvestre’s investigation (2022), the meaning and relevancy of the dormancy period itself remains undertheorized. It seems unlikely that charitable organizations identified in Howe and Sylvestre were registered and then sat for decades in anticipation of a future activation period. These classic burner charities (Gates of Mercy and Beth Oloth) were likely not originally registered with the expressed intent of becoming burner charities.

More likely, Gates of Mercy and Beth Oloth were originally registered with the intent of serving some type of legitimate charitable purpose, which simply did not manifest. Revivifying the husk of a pre-existing charitable organization for the sake of exploitation within a burner charity scheme, via, say, the insertion of complicit directors, etc., is arguably a comparatively simpler process than the paperwork required for registering a new charity. The opportunity for zombifying Gates of Mercy and Beth Oloth into burner charities may simply have presented itself. Without a dormancy period, KHM and CLY were still able to operate “actively” for years. The need for a dormancy period within a burner charity scheme—originally theorized as being useful in escaping CRA oversight—may be overvalued.

Gates of Mercy and Beth Oloth were the classic burners against which other revoked charities stood to be measured. These two appeared to operate with the highest degree of directorial overlap and synergy. Evidence of alleged shared bank accounts and directorial cross-pollination was highlighted by Howe and Sylvestre, as was the synchronous ebb and flow of donor charity-derived cash (2022). Such blatant operational overlaps were absent among the other five revoked charities. But, as will be discussed, evidence of donor charity participation, first theorized within the Gates of Mercy/Beth Oloth context, was evident across all revoked charities.

Exemplified by the extensive list of Israeli intermediaries it claimed to financially support, along with a public profile otherwise absent within the burner typology, Ne’eman Canada initially presented the potential of some type of hybrid typology. Rather than obfuscate its charitable purpose, Ne’eman Canada overtly announced its affiliation with a variety of intermediaries operating in financial complicity in the aiding and abetting of Israeli war criminality (see Howe 2024b. This arguably announced Ne’eman Canada as a war crimes conduit typology.

On the other hand, Ne’eman Canada’s total revenue was the most weighted to charity-sourced donations (78 percent of total revenue claimed during the activation period). As illustrated in Graphic 1, Ne’eman Canada also maintained the most significant interconnection to one single source of charity-affiliated wealth; donations received by Ne’eman Canada via two private foundations directly associated with the Friedberg Mercantile Group represented 34 percent of all revenue received by Ne’eman Canada during its activation period. One might posit that this depth of financial affiliation with charity-sourced donations brings the comparative importance and relevancy of Ne’eman Canada’s funding of Israeli intermediaries, via its website-based services, into question and announces the operations of a classic burner charity.

JNF Canada, at first glance, appears as the most obvious example of a war crimes conduit. Since its registration in 1967, JNF Canada has been formally aligned as the Canadian financial wing of the KKL, with all the expropriatory, settler-colonially infused activities that that has entailed. JNF Canada’s self-declared tax returns would suggest an organization exclusively supported by donations from the broader Canadian Jewish community; between 2003–23 it self-declared zero dollars sourced from other Canadian charities on Line 4510 of its yearly tax returns.

This, however, appears to be a case of misreported funding and does not tell the story of JNF Canada’s actual linkages to other Canadian charities. An ATI request to the CRA for a list of all donations to JNF Canada, from other Canadian charities, between 2000–23, yielded an extensive list of unique donors, totaling over $101 million CDN (CRA 2024p). The rationale behind this massive discrepancy in reporting is unknown and arguably brings a measure of doubt upon JNF Canada’s annual disclosures, in their entirety (see Howe 2025). Why, for example, would JNF Canada omit this revenue and what, in fact, is JNF Canada’s total revenue on a yearly and aggregated basis? What happened to this money? And how could the CRA have not known about this discrepancy in reporting, which went on at least between 2000–23? At the very least, this $101 million+ CDN in donations received from other Canadian charities illustrates the deep financial ties between JNF Canada and Canadian philanthropic foundations.

Finally, one must consider the role of Canadian charities, particularly private foundations associated with corporate and dynastic fortunes, within the movement of donations through the Canada to Israel philanthropic pipeline. Excepting the activities of Colel Chabad, private foundations made significant, repeated, usage of the revoked charities profiled in Findings(I). Each of the 56 aggregated or standalone entities identified and listed in Graphic 1, made significant donations to, on average, 3.4 revoked charities. As repeatedly noted, omitting baseline reporting requirements concerning recipient intermediaries renders impossible any further analysis of the purpose behind these donations, excepting in the cases of Ne’eman Canada and JNF Canada. All that can be said, in this regard, is that the donations were at the very least intended to go to Israel.

Certain aspects of this inter-charity participation in the activities of the revoked charities escape easy explanation. For example, several of the 56 identified standalones and aggregates identified in Graphic 1 are legally registered as charitable organizations. Why charitable organizations, which are legally conceived of as the frontline operators within the Canadian charitable sector, appear on a list meant to trace the source of charity-derived donations is unknown. Charitable organizations are not supposed to sit on pools of assets and so shouldn’t, technically, have millions of dollars on hand to move to other Canadian charitable organizations. The presence of secondary flow-through charities, holding donations temporarily as they move their way from private sources into (theoretically) Israel, further obscures the source points attached to the wealth itself.

Most charities listed in Graphic 1, however, are legally registered as private foundations. When one includes the $101+ million CDN received by JNF Canada from other Canadian charities (yet not claimed by JNF Canada as such), a tally of all revenue claimed by the seven revoked charities within their respective activation periods totals over $1 billion CDN. Of this, the charities represented in Graphic 1 were responsible for over $393 million CDN, or just under 40 percent of all revenue received. Compared to the rest of Canadian donors, these 56 entities clearly played an outsized role in financially underwriting the activities of the revoked charities.

As for accountability, no mention was made of inter-charity complicity in any of the CRA-produced NITRs associated with the revoked charities profiled in Findings(I). Their outsized financial participation in these alleged schemes of the Canadian charitable sector, which potentially defrauded the public sector of hundreds of millions of dollars in revenue, is literally erased. This, arguably, is the equivalent of an investigation that determines that a significant financial transgression of the Income Tax Act has taken place, which takes no interest in identifying the source of the money bankrolling the transgression.

CONCLUSION

In expanding the parameters of the two relevant case studies (Howe and Sylvestre 2022; Howe 2024) via a methodology reliant upon the ATI process, five more charities with self-claimed financial links to Israeli intermediaries, whose statuses had been revoked due to a failed audit, were identified. While characteristics associated with the war crimes conduit typology can be said to be associated with two of these (Ne’eman Canada and JNF Canada), burner charity typology characteristics can also be claimed for all seven. Cumulatively, a rough estimate is that upwards of $1 billion CDN was handled by these revoked charities during their respective activation periods.

Inter-charitable donations to revoked charities were financially significant and represented nearly 40 percent of all money handled by the revoked charities. The obvious financial linkages between donor charities and revoked charities, however, does not appear to be of interest to the CRA, from either an investigational or regulatory standpoint; no mention was made of these financial linkages in any of the associated NITRs.

As noted, this de-prioritization of financial complicity within the activities of revoked charities, despite ample and significant evidence of inter-charity participation, arguably falls within a crime of the powerful analysis of the philanthropic sector. CRA investigations, when they result in status revocations of transgressional charities, appear as overly narrow in focus. The result is that a core of repeat donors to illicit charities escapes identification and investigational interest. This is arguably a symptom of a philanthropic sector developed and maintained toward the financial benefit of these self-same donors. The analogy is of a system of justice focused upon penalizing the tools involved in a criminal activity, in this case charitable organizations, rather than the actual perpetrators/benefactors.

Affixing any measure of motivation onto the apparently illicit flows of money associated with the Canada to Israel philanthropic pipeline remains, for the most part, a conjectural exercise. This is in no small part because reporting requirements concerning intended Israeli intermediaries have, in many cases, simply not been met. Clearly, whatever the actual, overall, purpose was of the revoked charities, be it support for Zionist expansion, illicit money laundering, both, or other, philanthropic foundations contributed a significant percentage of their total received revenue. As noted, these same foundations, on average, made use of several revoked charities, and so there is some indication that their financial participation, whatever the motivation, is not the result of an accidental one-off.

Finally, one must consider the claims of anti-Muslim bias within the overall enforcement of the Canadian charitable sector. As of writing, such claims remain unresolved, due in no small part to the CRA’s refusal to disclose the algorithmic processes, training, etc., it utilizes when determining risks to the financial security of the charitable sector. Clearly, as demonstrated, illicit activity within the Canadian charitable sector is costly, both from a financial and reputational standpoint. Although such costs cannot explicitly be blamed upon inherent bias within the sector’s regulatory and enforcement processes, from a lay standpoint there is no reason not to believe that ameliorations are readily available. Charities that do not disclose their international intermediaries, for example, might easily trigger an automated, secondary, level of enforcement. Instead, such transgressions in baseline reporting are allowed to continue for decades.

The potential of such ameliorations, however, does nothing to address the underlying power dynamics that exist between the charitable organizations moving illicit funds, the private donors making use of said funds, and the law. As noted, none of the NITRs undertaken by the CRA made any mention of inter-charity movement of finance; this, despite the outsized participation of other charities. Until legislative modifications are built into the governing framework, the Income Tax Act, and until said modifications are backed up by rigorous enforcement, it appears clear that philanthropic crime will continue to thrive under a legal framework that punishes proverbial small fish, not those who benefit financially, if at all. At least for the non-Muslim-identified in Canada.

ENDNOTES

1 The CRA has audited JNF Canada multiple times (1977, 1981, 1985, 1995, 2011–2012, and 2016). Only the findings of the most recent audit are publicly available via NITR.

2 Both total revenue claimed and total revenue claimed from Canadian charities are highly problematic. See the “Considerations” section for details.

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