Has the 2024 Charitable Donation Deadline Truly Been Universally Extended?

In the final moments before the end of the year, the Government of Canada announced on December 30, 2024, that it is planning to extend the 2024 charitable donation deadline to February 28, 2025.

The announcement was made by the Minister of Finance and Intergovernmental Affairs, Honourable Dominic LeBlanc, and the Minister of National Revenue, Honourable Élisabeth Brière, who reported that upon the resumption of Parliament in 2025, the federal government will propose amendments to the Income Tax Act (Canada) to push forward the deadline for eligible donations beyond the usual year-end date. What is unclear is whether the extension will only be available to mail-in donations that were received after year-end by charities or if the extension will apply more broadly.

The key factor driving the extension is the Canada Post strike. Under normal circumstances, the date of a donation is the date a charity receives it. For donations made by mail, the Canada Revenue Agency (CRA) considers the receipt date of the donation as the date of the envelope's postmark. Given the strike, many mail-in donations may not have been sent or their receipt may be delayed by the stoppage, which could have negative consequences for both donors and charities. Charities want to ensure that they receive all intended year end donations and donors want to ensure that donations made by them in 2024 can be receipted this year. If donors are issued receipts by charities for the 2025 taxation year for 2024 intended donations, some donors may choose not to make additional donations to the same charities in 2025, resulting in the potential for lost revenue by the charities.

While the extension will provide benefits to charities and their donors, it could also be more burdensome for charities. The CRA’s existing policies address the issuance of donation receipts and receipt dates for mail-in donations. The CRA recommends that charities issue receipts for donations made in a calendar year by the end of February of the following calendar year. Given the extension of the donation deadline to February 28, 2025, it may prove challenging for some charities to issue receipts by that date. The CRA also recommends that charities keep copies of the stamped envelopes containing donations in their books and records to demonstrate when donations were received. This recommendation is of even greater importance now due to this donation extension.

If your charity, or you as a donor, have any questions regarding the extended 2024 charitable donation deadline, a member of our Not-for-Profit & Charities Group would be happy to assist.