April 11, 2024
Dear Minister Bibeau,
Over the past several years, you have been notified of concerns about a number of Canadian charities providing funds to organizations supporting the Israeli military and/or illegal Israeli settlements in the occupied West Bank. These include requests for investigations that are in violation of the Income Tax Act, R.S.C., 1985, c. 1 (5th Supp.), the Crimes Against Humanity and War Crimes Act, official Canadian policy, and international law.
From December 2022 until January 2024, the Director General and Director in the
Compliance Division of the Charities Directorate of the Canada Revenue Agency (CRA) received five specific requests for investigation of the Mizrachi Organization of Canada (119043891 RR 0001; herein: Mizrachi Canada). The Minister of National Revenue was copied on all of these requests, and copies were provided to the CRA National Lead Center.
We write to you today to inquire about the status of these requests. The fact that Canadian taxpayers are effectively subsidizing organizations such as Mizrachi Canada is deeply troubling, particularly considering its financing of Israeli organizations actively involved in the commission of war crimes under the Fourth Geneva Convention and Canada’s Crimes Against Humanity and War Crimes Act. This issue has gained additional urgency on account of the horrific situation presently unfolding in the Gaza Strip and West Bank, in which more than 33,000 people have been killed.
It must be stressed that Mizrachi Canada is one of several Canadian charitable organizations that we are aware of which actively finance illegal Israeli settlement and/or military activity, in contravention of Canadian and international laws.1 They include: the Jewish Heritage Foundation, the Ne’eman Foundation, the Canadian Zionist Cultural Association, and the Heseg Foundation. We focus here on Mizrachi Canada as but one example, thus indicating a need for a comprehensive policy solution to this larger problem.
Established and registered as a Canadian charity in 1979, Mizrachi Canada identifies its charitable objective as the “relief of poverty”. According to its tax returns, between 2018 and 2022 Mizrachi Canada cumulatively reported over $37 million in revenue and over $30 million in expenses, over 75% of which was devoted to administering “charitable programming” in Israel. Between 2018-2021, Mizrachi Canada neglected to identify which Israeli intermediaries were receiving these funds, contrary to its legal obligations as a Canadian charity.
2022 was the first year that Mizrachi Canada correctly listed recipient Israeli organizations in its tax forms. The 2022 filing contained several shocking revelations, including $100,000 that went to the Duvdevan Foundation, an Israeli charity that claims to offer support to current members of the Duvdevan Unit of the Israeli Defence Forces which, among other operations, engages in extrajudicial assassinations of Palestinians. To be clear, the CRA’s own guidelines note that increasing the effectiveness of another nation’s military is not considered charitable activity.
As we have also noted to you, Mizrachi Canada operates as the Canadian arm of the Israeli website ‘jgive.com’, and offers Canadian charitable tax receipts on behalf of Israeli charities. Among them are some of the most notorious Israeli organizations operating in the occupied Palestinian territory, and include:
- Regavim2, a radical pro-settler organization co-founded by far-right Israeli Finance Minister Bezalel Smotrich that works to dispossess Palestinians of their lands and facilitate illegal settlement in the occupied West Bank;
- Ir David3, an organization that aims to forcibly transfer Palestinians from occupied East Jerusalem with the objective of ‘Judaizing’ the city; and
- Kedumim, an illegal West Bank settlement that is home to both Smotrich and extremist settler leader Daniela Weiss, whose residents notably factored prominently in what Israeli military officials characterized as a pogrom4 in the Palestinian town of Huwara in February 2023.
Charitable organizations in Canada are supposed to work for the common good or benefit the public at large. It is difficult to see how support for these organizations would do that, not to mention that their activities run afoul of both international and domestic law, as well as the Department of Global Affairs’ public policy statement, which clearly positions Canada as opposed to illegal settlements in the Occupied Territories.
Mizrachi Canada appears also to be offering Canadian tax receipts to organizations directly complicit with the current Israeli invasion of Gaza, which the International Court of Justice has termed a “probable genocide.” They include:
- Im Tirtzu, a far-right Israeli organization that works to delegitimize Israeli human rights groups and progressive academics, equip the IDF “for victory”5, and which has been involved6 in the blocking of aid trucks to starving civilians in Gaza; and
- Women in Green7, a radical settler group whose current campaigns include one that allows donors to pay for Israeli flags to be planted by Israeli soldiers in the Gaza Strip and another with a campaign graphic that reads: “Victory for Israel! Demolish. Enter. Remain in Gaza!”
Mizrachi Canada listed both of these organizations, which are available as donation options on jgive.com, as recipients of funds in its 2022 tax filing. Mizrachi Canada’s website also offers an option for Canadian donors to directly earmark their charitable donations towards Im Tirtzu’s internationally illegal and morally reprehensible activities.
On March 1st, 2024, the Republic of Nicaragua issued proceedings in the International Court of Justice against the Republic of Germany, over the issue of arms sales to Israel. Allowing Mizrachi Canada to use Canada’s charitable sector as a state-sanctioned financial conduit for the expulsion of the Palestinian people from Gaza leaves this country potentially vulnerable to similar such proceedings within the ICC.
We are asking you to take immediate steps to:
- Revoke the charitable status of Mizrachi Canada for its flagrant abuse of its own Canadian charitable status, as well as for the disrepute it has brought upon the Canadian charity sector as a whole;
- Undertake an immediate and thorough investigation of all Canadian charities providing funds to Israeli settlement organizations and/or support to the Israeli military;
- Publish clear policy guidelines clarifying that supporting illegal Israeli settlements and the Israeli military are not legitimate charitable activities; and;
- Establish an advisory committee comprising a diversity of community groups, towards advising the minister on existing and future transgressional activity.
We look forward to your prompt response.
Sincerely,
Karen Rodman, Executive Director, Just Peace Advocates
Corey Balsam, National Coordinator, Independent Jewish Voices Canada
Miles Howe8, Adjunct Professor, Brock University Department of Sociology
Cc:
Iqra Khalid, Parliamentary Secretary, National Revenue
Adam Chambers, Conservative Shadow Minister, National Revenue
Niki Ashton, NDP National Revenue Critic
Jean-Denis Garon, Bloc Québecois National Revenue Critic
Sharmila Khare, Director General, Canada Revenue Agency (CRA)
Melissa Shaughnessy, Director of Compliance, Compliance Division, Charities Directorate, CRA
- See Miles Howe and Paul Sylvestre, (November, 2022), International Cash Conduits and Real Estate Empires: A Case Study in Canadian Philanthropic Crime, Journal of White Collar and Corporate Crime, https://journals.sagepub.com/doi/full/10.1177/2631309X221138974; Karen Rodman, (December 18, 2023) CRA asked to investigate charities supporting Israeli military, Rabble https://rabble.ca/politics/canadian-politics/cra-asked-to-investigate-charities-supporting-israeli-military. ↩︎
- See Defund Racism, (2023), Regavim: How Charitable Donations are Funding Indigenous Erasure, https://defundracism.org/wp-content/uploads/2023/09/DefundRacism-Regavim.pdf.
↩︎ - See Alex Kane, (May 14, 2021), Tax Exempt US Non-proutfits fuel Israeli settler push to evict Palestinians, The Intercept, https://theintercept.com/2021/05/14/israeli-settler-evictions-jerusalem-nonprofits/
↩︎ - Joshua Davidovich, (28 February 2023), “Settler extremists sowing terror, Huwara riot was a ‘pogrom’, top general says”, Times of Israel, https://www.timesofisrael.com/liveblog-february-28-2023/.
↩︎ - Im Tirtzu, (Accessed April 1, 2024), Equipping the IDF for Victory, https://www.charidy.com/imtirtzu/
↩︎ - See Im Tirtzu, (March, 2024), Im Tirtzu’s Special Missions Coordinator Reveals Successful Efforts to Thwart Aid Deliveries to Hamas, https://imti.org.il/en/66087/; The New Arab, (March 28, 2024), Dozens of Israeli protesters block Gaza aid convoys at Kerem Shalom crossing, https://www.newarab.com/news/dozens-israelis-block-gaza-aid-convoys-kerem-shalom
↩︎ - Women in Green-Women for Israel’s Tomorrow, Jgive.com (accessed April 1, 2024) https://www.jgive.com/new/en/cad/charity-organizations/2759/projects
↩︎ - Dr. Miles Howe is the co-author of ‘International Cash Conduits and Real Estate Empires: A Case Study in Canadian Philanthropic Crime’, which appears in the Journal of White Collar and Corporate Crime, and the forthcoming author of ‘Zionist Philanthropy and Palestinian Erasure: Jgive.com and the Mizrachi Organization of Canada’, which will appear in the April/May 2024 issue of State Crime Journal.
↩︎