Request for CRA Investigation of CHIMP & Its Network of 200 Vancouver Charities: Updated April 23, 2023

Figure CHIMP vs Vancouver Foundation (2015-2022)

Updated April 23, 2023

For many charities, it's hard to raise money but not for Charitable Impact Foundation, a Vancouver charity known as CHIMP.

Last year, towards the end of April, CHIMP reported that it had hit a big milestone: ONE BILLION dollars in donations. Within two weeks of that, CHIMP was up by another $100 million. But since then, CHIMP's reported, total donations hasn't increase at all. Its currently sitting at $1.1 billion, same as a year ago.

To put CHIMP's size and spectacular growth into perspective, it helps to compare with Vancouver Foundation which has been the biggest charity in the city for 75 years. In terms of tax-receipted donations, CHIMP, a relatively new charity, reported almost five times as much as Vancouver Foundation in 2021, and even more in 2022.

(NOTE: Vancouver Foundation is not affiliated with CHIMP. I mention it simply as a point of comparison). 

CHIMP is a federally registered charity set up by Blake Bromley, a retired, Vancouver lawyer who specializes in tax planning. CHIMP is run by Bromley's sons, John and Clif.

Blake Bromley claims to have set up 650 charities that handled $2 BILLION worth of charitable giving. That's a lot of money, and a lot of potential tax relief. 

Over the past five years, I have identified about 200 charities that were set up by Bromley's business. Since nearly all 200 charities are run out of the same office, that of Bromley's former company, and most of their directors are his former employees, I call them "the Bromley Charities."

Two of the largest projects of the Bromley Charities are Quest University Canada in Squamish and Fortius Sport & Health Centre in Burnaby, B.C (now named Christine Sinclair Community Centre).

The Bromley Charities that started the university and the sports centre reported MORE THAN HALF A BILLION DOLLARS in tax-receipted donations and gifts ($425 million and $106 million, respectively). With that level of support, both the university and the sports centre should have been in good shape financially but that was not the case. In 2020, the university was forced into foreclosure by one of the Bromley charities, Vanchorverve Foundation. The sports centre also closed, citing financial difficulties, and was sold to the City of Burnaby for $26.6 million.

As a result of its sale, Quest University lost ownership of all its land and buildings and is now reduced to leasing its campus from the new owner.

The sale of the university and the sports centre resulted in huge payments to The Bromley Charities for $26.6 million and $25.6 million, respectively. Thus, the Bromley Charities appear to have benefited substantially from the demise of their own projects. That's charity?

Just a few years ago, CHIMP gave a gift of $74.7 million to Fortius Foundation, the charity that built and owned the sport centre before it was sold. If that $74.7 million was of true economic value, there's no way that the sports centre should have needed a $25.6 million dollar bail-out from Burnaby taxpayers.

In my opinion, what appears to have happened is that both the university and the sports centre were financed primarily by "gifts" that were actually loans. The loans were kicked down the road, re-financed multiple times while the Bromley charities collected millions of dollars of interest on the loans. When the university and the sports centre were sold, the Bromley charities got their money back, not far from what The Globe & Mail first reported, nearly four years ago.

The question is, why is the CRA allowing this to go on so long?

To continue reading, click here.

Posted at 12:47 AM | | Comments (0)

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11/22/2023

Affidavits: Vivian Krause, Nov. 16, 2023

Exhibits to Vivian Krause Affidavit:

 

Posted at 07:01 AM | | Comments (0)

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11/03/2023

Why Vivian Krause Is Being Sued - And Filed for Dismissal

Fortius Sport & Health Centre

Dear Friends,

This is to explain why I am being sued for defamation and why I have filed for dismissal.

Over the years, as I have been following the funding of various causes, I have exposed the fact that some of the largest "charitable gifts" in Canadian history are a sham. As The Globe & Mail reported, in some cases, the donor got a tax receipt and got their donated shares back too. That's not a true gift so doesn't deserve a tax receipt.

Here's a few examples of large so-called "gifts" that weren't true in the sense that the "donor" got back "donated" shares, or a tax receipt was issued far in excess of  true value:

  1. $ 15,000,000
  2. $ 23,000,000
  3. $ 30,000,000 
  4. $ 30,560,060
  5. $ 45,175,000
  6. $ 70,000,000
  7. $ 74,711,535

That's seven gifts for $288 million.

The above amounts were towards a sports centre and a university:

Despite half a billion dollars in charitable gifts, both Fortius and Quest ended up in deep debt and were sold. The funny thing is, the "debts" were to the same charities that made the "gifts."

The so-called "gifts" for $23 million and $74 million went to Fortius Foundation.

In 2021, I wrote letters to warn the City of Burnaby against paying $26 million in cold hard cash to Fortius Foundation for the sale of its sports centre. At the very least, I urged the City to do more due diligence. Later that year, a defamation claim against me was filed by Fortius's founder. What I didn't know then is that Fortius was under a four-year CRA audit. The very same week that I was sued, CRA sent a letter to Fortius saying that its charitable status would be revoked - but I didn't learn that until two years later.

Fast forward to this year and CRA has now revoked Fortius because of egregious violations (as of July 29 2023). The person who is suing me applied for an injunction against CRA from the Federal Court of Appeal. When that was denied, he applied to the Supreme Court of Canada. Both courts dismissed the matter.  Nonetheless, I am still being sued.

I have filed a motion for dismissal. Court is scheduled for December 7 & 8, 2023.

Below, here's some background and more details ...

BACKGROUND

The charity at the centre of this is "Charitable Impact Foundation," originally called "CHIMP Foundation," and known as CHIMP.

CHIMP says that it has received $1.2 billion and claims to be the "fastest-growing" charity in Canada. But, as I have said umpteen times at this blog, there are many signs of monkey business at CHIMP. For example, a few years ago, Deloitte, CHIMP's independent auditor, warned that it could not vouch for $193 million of CHIMP's unlisted securities.

One of the reasons I followed CHIMP is that it is part of a large network of charities, all set up by the same person, Blake Bromley, a tax lawyer, now retired.

Blake Bromley claims to have set up 650 charities that handled $2 billion.

One of the reasons that I am concerned about the Bromley charities is that some of them issue tax receipts for huge amounts. For example, last year, a charity that was originally set up by Bromley issued tax receipts for $512 million for real estate properties. That was the single largest amount of non-cash, tax-receipted gifts made by any charity in Canada last year. 

Its not only the Bromley charities that receive gifts of real estate. Last year, another charity issued tax receipts for $139 million for real estate properties. These very large gifts of real estate warrant more scrutiny.

Over the years, I found so many red flags that during 2021 and 2022, I wrote letters to CRA requesting audits of the Bromley charities, including CHIMP.

Since last year, 19 charitied handled by Bromley have been revoked. Most of those were under audit well before I wrote to CRA.

CHIMP and Tides Canada (Makeway)

More than ten years ago, CHIMP first came on my radar because it funded Tides Canada (now called Makeway). The funny thing was, CHIMP’s first gift to Tides Canada was only $9 (nine dollars). Surely that was a typo, I thought, until I dug up CHIMP's tax return and found that CHIMP makes very small gifts to thousands of charities. In fact, CHIMP has made more than 10,000 gifts for $97 or less. More about this in a subsequent post.

My concerns about Tides Canada were two-fold: I was concerned about its activism and its Exchange Fund.  While the activism funding got media attention, the Exchange Fund didn’t. 

TIDES CANADA EXCHANGE FUND

The Exchange Fund was the first case of circuitous "gifts" that I noticed. The problem with such "gifts" is that they enable a donor to get a tax receipt without making a true gift. Charities should not engage in this at all.

In 2016, I wrote a paper about Tides Canada’s Exchange Fund and presented it to a Senate Committee as part of my testimony on the funding of activism against Canadian pipelines to export Alberta oil. Within weeks, there was an announcement that the Exchange Fund had been closed.

My concern about Tides Canada's Exchange Fund is that some of its transactions were circuitous. For example, an American company based in Pawtucket, Rhode Island, set up a registered charity in Mississauga. The charity issued tax receipts to the Pawtucket company for about $3.5 million and then transferred the entire amount to Tides Canada in Vancouver. If Tides Canada had spent that money on charity in Canada, that would have been great! But that’s not what happened. Instead, Tides Canada forwarded the money back to Pawticket via The Tides Foundation in San Francisco, using the Exchange Fund as the conduit. The American company’s donations did end up in two charities in Pawtucket. However, it does not seem right to me that the company got tax credits which could have reduced its taxes in Canada but then the "donations" went straight back to the US.

Another charity, Sentry Foundation was revoked solely for using Tides Canada's Exchange Fund and yet Tides Canada itself was not revoked. Seems inconsistent to me. 

Around the same time as the Alberta Inquiry, I noticed several changes in the funding of activism. One of the top-funded organizations, Sisu Institute, simply closed. As for Tides Canada, it became the #1 top recipient of funds from CHIMP.

TIDES CANADA: CHIMP"s #1 TOP RECIPIENT

Last year, Tides Canada received more funds from CHIMP than any other organization, a total of $8.1 million (including $193,075 for Hollyhock).  In total, Tides Canada has received $10.8 million from CHIMP, tax returns show.

Before I go any further, let me be very clear: I do not allege that Tides Canada is part of CHIMP’s monkey business.

But here the thing: If CHIMP wasn’t funding a large number of diverse organizations, the suspicious gifts that CHIMP makes would stick out like a sore thumb, like for example, CHIMP's $74 million gift to Fortius Foundation.

And now, finally, this bring me to why I am being sued…

CHIMP'S $74 MILLION GIFT

In 2019, when I noticed CHIMP’s $74 million gift, I wrote to Fortius Foundation, the recipient, and asked, hey, what’s the $74 million for? Pretty big gift. What are you doing with the money? No reply.

In 2020, Fortius Foundation announced that "pandemic pressures" forced the foundation to sell its sports centre. Huh? I couldn’t believe it. How could they be in any financial trouble having received $74 million just two years earlier? I obtained financial statements for Fortius Foundation and found out that, in fact, by 2017, long before COVID, Fortius already had a "debt" of $94 million. So no, it wasn't COVID that got Fortius into big trouble.

I tried and tried to contact the founder of Fortius Foundation. No response from him nor CHIMP so I wrote to the Mayor & Council of the City of Burnaby and urged them to do more due diligence before giving Fortius Foundation $26 million in cold hard cash for its sports centre. I also went to the RCMP – and I made no secret of that.

In an abundance of transparency, I made it publicly known (in my letter to Burnaby's Mayor & Council) that I had gone to the RCMP. My intention was to give the founder of Fortius every opportunity to correct me if I had said or written anything that was factually incorrect.

In September of 2021, the founder of Fortius filed a defamation claim against me.

THE $23 MILLION TRANSACTION

The founder of Fortius has claimed that he made a gift of $23 million for the sports centre. He told The Globe & Mail that he gave away "most of his personal fortune," including the inheritance of his wife & sons in order to make what Fortius called "the single largest" gift in Canadian sports history. But financial statements tell a dramatically different story.

According to financial records, Fortius started not with a gift but a debt of $23 million on a high interest loan (initially at an interest rate of 20 percent). The founder's family had a private foundation and it had a promissory note (that's like an "I.O.U.") for $23 million. So no, as I see it, there was never any true gift of $23 million.

As for the purported "gift" of $74 million, it is, in my words, a circular, self-cancelling transaction whereby the entire "gift" of $74 million was effectively unwound and the donor charity, CHIMP, got back the entire $74 million.

At the end of May of 2022, the Burnaby RCMP completed and forwarded its report to CRA. Also at the end of May of 2022, my legal counsel filed, on my behalf, a motion for dismissal of the claim against me on the grounds that it is without merit. Also filed, an affidavit (600 pages of exhibits). Not too long after that, on July 21, 2022, CRA notified Fortius that it would be revoked.

CRA AUDIT OF FORTIUS

According to CRA's audit, Fortius Foundation provided undue benefits to its founder’s for-profit business, in two ways: 1) there was an "unwritten expense sharing agreement" whereby the salaries at a for-profit company of the charity's president were being paid for by the charitable foundation, and 2) the foundation effectively provided the sports centre to the for-profit business on a rent-free basis. According to CRA, rent was not collected for six years in a row. CRA calculated that the undue benefits total $12.3 million and characterized Fortius 's violations as "egregious."

CRA audited Fortius Foundation but strangely enough, CRA did not audit Fortius for 2018 when it received the $74 million gift from CHIMP. However, CRA did audit and revoke Homestead on the Hill Foundation, one of the seven charities involved in effectively unwinding CHIMP's $74 million gift. CRA found that Homestead's gift to CHIMP, the only gift that Homestead made over eight years, was part of  "a series of pre-determined transactions used to artificially inflate tax benefits for certain corporations and/or individuals and to allow other charitable entities to falsely meet its disbursement quote so that they may avoid revocation." So there we have it.

Never again should any one of the largest “charitable gifts” in Canadian history be a sham.

Posted at 01:36 PM | | Comments (0)

Tags: $74 million gift, Blake Bromley, charities, CHIMP, CRA, fake gifts, Fortius, John Bromley, Scott Cousens

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10/28/2023

Tax-Receipted, Large NON-CASH Gifts: A Call for Audit, Starting With CHIMP

Pushing our national debt to $1.2 trillion, the federal government's deficit for 2022 was $35.3-billion. Next year, it is forecasted to be about the same. As one of many measures needed to reduce our daunting deficit, here’s an offbeat idea:

CRA should audit the issuance of tax receipts for large, non-cash donations, especially real estate properties, life insurance premiums, cryptocurrency and so on.  These tax receipts are issued charities, a small number of which are anything but charitable. These should not be allowed to stain the reputation of charity in general.

Of course, charity audits won’t close a billion-dollar budget gap. But stopping the tax dodgers would increase government revenue. Every bit helps. The fairness & integrity of our tax system would also improve.

Under Stephen Harper, almost 800 charities were audited per year. Since 2015, that number has fallen. Only 182 audits were completed last year.  By CRA’s own admission, audits account for only 3 percent of the compliance-related activity conducted by the Charities Directorate.

Fig CRA Audits (2011-2022)

To be clear, I’m not calling for audits of small charities. I call for audits of the big ones, those that issue tax receipts for hundreds of millions of dollars. I arrive at this idea based on three years of intensive research involving more than 50 requests for information from CRA and my review of the CRA audit reports on 19 charities who have had their status revoked by CRA for serious non-compliance. 

After the controversy over the political activity of charities, a decade ago, another call for charity audits (especially from me!) is bound to draw groans, moans and eye rolls. But hear me out…

Most of my research and my correspondence with CRA has been about 200 charities set up by a single person, a tax lawyer, now retired.

Over the past year, CRA has revoked (read: closed) a total of 19 charities handled by the same tax lawyer whom I’ve been following for many years.   It is important to note that the 19 charities are not typical.  Their bad behaviour must not tarnish Canadian charities as a whole.

What is important here is what the 19 CRA audits reveal about CRA.

$21 BILLION

For 2021, charities issued tax receipts for $21 billion (CRA e-mail & Excel spreadsheet).  Most of that gets issued by relatively few charities that issue tax receipts for BILLIONS of dollars. The part that concerns me is the NON-CASH gifts because the valuation of these gifts is so open to abuse.

For 2021 and 2022, as few as 20 charities issue tax receipts for non-cash gifts for about $1.7 billion per year. Some of these are not well-known charities, most people have never heard of them. Last year, one foundation alone issued tax receipts for $512 million including $505 million for real estate properties.

Tax receipts translate into billions of dollars in tax credit. That’s revenue that government doesn’t collect in order to incentivize charitable giving.  To the extent that charities benefit the public and that these benefits justify the lost revenue, the tax credits make sense.

But here’s the problem:

A growing body of evidence, including CRA audit reports, shows that some of the largest tax-receipted gifts in Canadian history were not true gifts. These gifts are a sham and, therefore, not deserving of a tax receipt.

For a gift to merit a tax receipt, it must be a true gift. In technical terms, this means that the donor must not get any benefit nor advantage from having made the gift. Most certainly, the donor is not supposed to get a tax receipt and then get their gift back too.

As I mentioned earlier, CRA has revoked 19 charities handled by the same guy. I could say his name but lets leave that out for now. Lets focus instead on the CRA’s handling of his charities.

The 19 CRA audit reports, provided to me upon request, indicate that most of the revocations were because of complex schemes that conferred undue tax benefits.

In one case, tax receipts were issued for $32 million for donated shares and then the same shares were returned to their donor via 19 transactions spanning seven years.

In a second case, a charity issued a tax-receipt for (14) $30 million ($30 560 060) for donated shares, also returned to their donor. Two of the three charities involved have been revoked by CRA. One of these is HSEF Renaissance Academy (“HSEF”).

In a third case, the Association for the Advancement of Scholarship (“AAS”) also issued a tax receipt for $30,000,000 and again, the donor got back the donated shares.

TEN YEAR DELAY, ON AVERAGE

The timeline on CRA’s revocation of the 19 charities is appalling.

On average, my research finds that there was a ten year delay between the audited transactions and revocation. In the case of HSEF, the delay was 21 years. The shares were donated in 2001 and HSEF was finally revoked last fall.

For AAS, the audit report was finalized in 2012. CRA sent the notice of intent in 2013 but then it took another 10 years before revocation as of March 25, 2023.

A fourth, more recent case, involves a charity whose founder claimed that he made "the single largest philanthropic gift in Canadian sports history.” This foundation built a sports centre and owned it until the centre was sold to the municipal government, the City of Burnaby. The name of it is Fortius.

As The Vancouver Sun reporter, Dan Fumano has reported, Fortius had an "unwritten expense sharing agreement" whereby it paid the salaries of staff at a for-profit business owned by Fortius Foundation's president. A CRA audit discovered that Fortius leased its sports centre to the for-profit business but then didn’t collect any rent for six years in a row. Effectively, the business got almost $12 million worth of free rent, according to CRA. In CRA’s terminology, this is called “undue benefits.”

LEGAL ACTION

Now, full disclosure:

Two years ago, Fortius’ founder filed a defamation claim against me after I tried to warn the City of Burnaby against paying $26.6 million in cold hard cash for the purchase of the sports centre. Under the Strategic Litigation Against Public Participation Act (“SLAPP”), I have filed a motion for dismissal, along with an affidavit and 600 pages of exhibits. Court is scheduled for December.

On the grounds that CRA had allegedly been "influenced" by me, an application was filed with the Federal Court of Appeal for an injunction to stop CRA. That request was dismissed. An application was also made to the Supreme Court of Canada and again, it was dismissed.

My main concern with Fortius is that it got one of the biggest gifts in Canadian history, a gift of $74 million. The problem is, this so-called “gift” was effectively unwound or reversed. In the end, the donor charity wasn’t out by a dime.

CHIMP'S $74 MILLION "GIFT"

This part is a bit complicated so bear with my will I try to explain…

As I have shown with the exhibits that accompany my affidavit, the entire $74 million and more was returned under the banner of the payment of “loans” involving seven, affiliated charities. Three of the seven have recently been revoked by CRA (Fortius, AAS & Homestead) meanwhile the charity that made the $74 million gift, CHIMP, and three more remain active.

How CHIMP's $74 Million Gift Was Unwound

One of the revoked charities is Homestead on the Hill Foundation (“Homestead”). A CRA audit of Homestead found that “a gift made by the Foundation (Homestead) to CHIMP for the 2018 fiscal period was not a gift made to a qualified donee in support of its charitable activities but rather a series of predetermined transactions used to artificially inflate tax benefits for certain corporations and/or individuals to allow other charitable entities to falsely meet its disbursement quota so that they may avoid revocation.”  So there we have it.

The charity that made the $74 million gift is Charitable Impact Foundation, known as “CHIMP.”

Its not as if CHIMP is a small charity run by volunteers. CHIMP boasts that it is the“fastest-growing" charity in Canada. CHIMP claims that it has received $1.2 BILLION in donations. Tax returns show that CHIMP has issued tax-receipts for $800 million. Last year alone, CHIMP issued tax receipts for $196 million.

RED FLAGS

Its not as if there have been no red flags. Three years ago, Deloitte, CHIMP’s independent auditor, warned that Deloitte could not vouch for $193 million of CHIMP’s unlisted securities. Shortly after that, CHIMP’s entire board resigned.

For 2021, CHIMP ranked 11th out of all 86,000 Canadian charities in terms of tax-receipted gifts, according to CRA.  For non-cash, CHIMP ranked 5th.

FIFTH. Think about that.

Surely such a large charity is on CRA’s radar… or is it?

What does it tell us about CRA that by CRA’s own admission, a $74 million gift, one of the largest in Canadian history, was a sham, and yet, six years later, the charity that made that sham gift is issuing tax receipts for hundreds of millions of dollars? In fact, since 2018, CHIMP has issued tax receipts for $700 million.

Its time for proper investigation of this monkey business.

Posted at 10:09 PM | | Comments (0)

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09/14/2023

Letter to Quest Alumni & Friends

QUEST

 

Dear Alumni & Friends of Quest,

As we know, Quest's campus has been sold to Capilano University.

While I wish Capilano the very best, I am sad (and angry) about what happened to Quest and would like to see Quest's program revived.

Personally, I have never had any involvement with Quest but I have done a lot of digging into its financial history.

My heart goes out to all the students, especially the international students, who have now lost their alma mater.

As I've been wondering what to do next, I got thinking about Newfoundland.

Newfoundland used to be a nation but because of  WWI and mismanagement, Newfoundland got in deep debt. In the 1930s, they had to give up their nationhood and go under the wing of the United Kingdom. It took almost 20 years before Newfoundland got back on its feet again as a province of Canada.

This got me thinking ... maybe Quest could come back as Quest Institute at Capilano. This would provide Quest with the benefits of being part of an established university. Capilano would also benefit from Quest's innovative approach to teaching and learning, and a trail-blazing, international alumni of dynamic young people from 40 countries around the world. Sounds like a win win to me. To be clear, I have not spoken with anyone at Cap.

But how on earth could Quest get on its feet again?

Here's my initial thoughts, but first, a bit of background:

On July 29, 2023, just days before Quest’s sale was announced (August 16), CRA revoked Eden Glen Foundation, one of the many charities involved in the sale of Quest’s original land. Upon request, I received CRA’s audit report on August 4, 2023. To my surprise, CRA’s audit report reveals that beneficial ownership of Lot 12 (about 12 acres) is currently held by Stewart Blusson, Quest’s original benefactor.

On August 14, 2023, I spoke with Mr. Blusson. He confirmed that he holds beneficial ownership to Lot 12 and also Parcel A, a large section of land. Together, Parcel A and Lot 12 are worth somewhere around $30 million.

Seems to me that Mr. Blusson could be offered a proposal for how this land could be used to fulfil his original dream, which was to help start in Canada, a university like the one that he attended in the U.S. where he learned the skills he later used to pioneer the diamond industry in northern Canada.

Over the years, based on my digging into Quest’s financial history, it has become clear to me that Quest is a victim of a massive tax scam and a miscarriage of justice. As for Mr. Blusson's philanthropy per se, he hasn't been heard from yet, at least, not officially.

I can see why Mr. Blusson would not have wanted Parcel A and Lot 12 in the hands of Quest during the years that Blake Bromley and others were involved. But that has now changed.

The first step, in my view, is to get proper legal counsel. This is why I support the GoFundMe to cover legal fees, started by Quest alumni in early August. To those who are able to chip in, here's the link:

Here's a document that I hope will help get legal counsel up to speed, once it is retained:

More here: Quest: Victim of a Massive Scam & Miscarriage of Justice

Looking forward to hearing your thoughts. I'd love to hear from you. You can comment here or shoot me an e-mail at [email protected].

Sincerely,

Vivian

Posted at 02:38 PM | | Comments (0)

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Red Flags: The Case for Legal Counsel Regarding Quest

Quest Photo

On the basis of my research it is clear to me that Quest University is the victim of a massive scam and a miscarriage of justice.

Here's the detailed document that I've written to explain how I believe that Quest got shafted:

Here’s the key points of my report:

Fundraising and high-interest loans to Quest were handled by Blake Bromley, a tax lawyer, via a series of charities that he set up and ran ("the Bromley charities”). These include Charitable Impact Foundation, (“CHIMP”) run by Bromley’s sons, John and Clif.

CHIMP claims to be the "fastest growing" giving network in Canada. But there are signs of trouble. A few years ago, Deloitte, CHIMP's auditor, could not vouch for $193 million of CHIMP's unlisted securities.

Over the same years that Quest floundered and was lost, CHIMP has reported $1.2 billion in donations. Tax returns clearly show that this includes $145 million that originated from charities involved in Quest’s financial history. As sexamples of the Bromley charities that transferred funds to CHIMP, consider Almoner Foundation and Vanchorverve Foundation:

Not only CHIMP received $145 million from charities involved in the sale of Quest’s land, the lease and sale of a student residence, royalty income, interest on loans and more, CHIMP has paid $68 million to a private company owned by Bromley & his son, John Bromley.  Payments to that company have soared from $50,000 to $13.6 million per year. I am concerned because I cannot account for the origin of the $68 million via proper sources. This raises concern in my mind that some of the $68 million originated from Quest and is rightly owed to Quest.

CHIMP provides a website that facilitates donations to any one of the 86,000 charities in Canada. CHIMP website is "free" to use, CHIMP says. On donations of $1,000,000 or more, CHIMP charges 0.5%. Even if CHIMP had charged 0.5% on the entire $800 million in tax-receipted gifts that CHIMP has reportedly received since it began (according to its its own tax returns), that’s only $4 million.

So where did CHIMP get the $68 million?

Miscarriage of Justice

Over the past year, CRA has revoked (read: shut down) 19 charities handled by Bromley. The CRA audit reports on these charities reveal that they were part of massive tax scams involving bogus charitable “gifts” for hundreds of millions of dollars. The reason I refer to these gifts as “bogus” is because they were not true gifts in the sense that the donors got back their donated shares, or because the shares were tax-receipted far in excess of their true value, or because the “gift” was not made without the expectation of something in return. In such cases, the “gift” was a transaction that was not a true gift. Most of the CRA audits were done years ago. In fact, the average delay between the audited transactions and revocation was TEN YEARS.

Several of the CRA audit reports (HSEF, HSSF & AAS) were available years before Quest went into default and under CCAA, and yet the CRA audit reports did not come up in court. In fact, the CRA audit report on the Association for the Advancement of Scholarship was completed in 2012 and then it took ELEVEN YEARS before its charitable status was finally revoked as of March 25, 2023.

Had the CRA audit reports come up in court, I believe that Quest’s debt would have been scrutinized more closely, that the court would have seen that Quest was the victim of a massive scam in which some of Quest's land was finagled away and Quest was burdened with high-interest loans (eg. 15 percent) instead of the tax-receipted gifts that were Quest's due. This is why I believe that Quest was a victim of a not only a massive scam but also a miscarriage of justice.

I acknowledge that the allegations and questions that I am making here are serious. I do not raise these lightly. I am already being sued by one of Bromley's clients. 

It is unacceptable that an entire university is brought down by a tax scam.  Furthermore, the issues raised by Quest's downfall are important to the integrity of our tax system.

This spring, in a genuine attempt to verify my analysis, I sent ten letters to Blake Bromley, John Bromley & various associates, a total of 915 pages. So far, no response. In the absence of any response from Mr. Bromley and others, I wrote this document to compile my analysis, opinions, questions & concerns:

  1. CRA Audits Key Findings
  2. Global Charity Fund
  3. Parcel A & Lot 12
  4. 1012986 BC Ltd. (Stewart Blusson)
  5. Almoner Foundation
  6. Charitable Impact Foundation ("CHIMP") Real Estate Transactions

Please note that this document is marked DRAFT. The reason that it is still in draft format is because I have sent it to Blake Bromley, John Bromley, Stewart Blusson and others, and have not yet received their feedback. Once I do, I will revise and finalize this document.

Posted at 02:18 PM | | Comments (0)

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08/14/2023

Quest Alumni Urge Immediate Pause in Capilano University to Purchase of Quest

 

Quest University students are requesting an immediate pause in plans for Quest to be purchased by Capilano University.

Posted at 12:15 AM | | Comments (0)

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05/09/2023

Testimony to the House of Commons Committee on Foreign Election Interference May 9, 2023

Opening remarks, click here.

RE: Leadnow

Re: We Charity

Other materials referred to:

 

Posted at 03:31 PM | | Comments (0)

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05/01/2023

Letters to Blake Bromley RE: Quest

Letter to Blake Bromley

On February 20, 2023, Quest University announced that it is suspending all academic operations due to financial troubles. In my view, this suspension is tantamount to closure. Since this announcement, I have written eight letters to Blake Bromley and his colleagues, starting with a letter to Ms. Anne Lawlor, the former CFO of Sea to Sky Foundation, on March 1, 2023.

Here's the eight letters and attachments:

  1. March   1, 2023: Sea to Sky Foundation   Sent to Anne Lawlor, former CFO of Sea to Sky
  2. March   3, 2023: Almoner Foundation Also: ATTACHMENTS
  3. March   7, 2023: Foundation for Public Good, Vanchorverve & CHIMP ATTACHMENTS
  4. March 10, 2023: Mortgage Loan from BHP Billiton Diamonds & Parcel A APPENDICES
  5. March 27, 2023: $68 Million Paid to Chimp Tech Inc.
  6. March 29, 2023: Funds from Outside Canada
  7. April   18, 2023:  Association for the Advancement of Scholarship
  8. May      2, 2023:  $70,000,000
  9. May     16, 2023: Global Charity Fund ATTACHMENTS
  10. June 7, 2023:      E-mail
  11. November 17, 2023: CHIMP Real Estate Transactions, November 17, 2023  
    1. CHIMP: 34 Real Estate Properties $37 Million (2022)
    2. The Bromley Charities: 188 Real Estate Properties
    3. Almoner Foundation: 83 Residential Apartments
    4. CHIMP: 10,000 Gifts $99 Or Less

For the e-mail sent to Blake Bromley & colleagues, May 4, 2023, click here.

For a file with the 10 letters, excluding attachments, click here.

For the 10 letters including attachments, click here. NOTE: This is a large file (915 pages).

For letters sent to Blake Bromley, John Bromley & the Quest Board of Governors, click here.

For letters sent to Blake Bromley, John Bromley & Scott Cousens, click here.

Data analysis tables:

  1. Gifts Between 15 REVOKED Charities (2000-2021)
  2. How Gifts from Global Charity Fund Were Re-Gifted To CHIMP
  3. CHIMP: Top 100 Gifts (2022)
  4. CHIMP Gifts (2022) Summary
  5. CHIMP Gifts >$1 000 000 (2011-2022)
  6. CHIMP Non-Arms Length Gifts By Year (2011-2022) (Top 20 Only)
  7. Gifts To CHIMP from Bromley charities: $242 Million
  8. Analysis of Gifts from 35 Bromley Charities $308 Million (2015-2021)
  9. 500 Gifts Between Bromley Charities for a total of $876 Million (2000-2021)
  10. Fees Paid by 70 Bromley Charities (2003-2022)
  11. Interest Income Earned on 40 Loans: $28 Million
  12. Losses on FMV of Investments: $302 Million
  13. CHIMP, Arcadia Foundation, Rosewood Charitable Foundation & Angel Philanthropy Foundation
  14. Howe Sound Samaritans Foundation: Overview (2012-2022)
  15. CHIMP Top 20 Gifts (2016)

Posted at 01:48 PM | | Comments (0)

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04/23/2023

CRA Kept Quest In The Dark 21 Years

Quest on a starry night

Quest University, Canada's first independent, secular university, has closed. In April, owing to financial trouble, Quest held what may well be its last commencement ceremony.

From 40 countries around the world, students came to Quest for its unique, undergraduate degree in both arts and sciences at a state-of-the-art campus in the spectacularly beautiful mountains of Squamish, B.C.

As the hopes for a world-class, independent university come crashing down, it is important to look back at what happened, and why.

Having done detailed research on Quest’s early financial history, it is clear to me that CRA’s lax oversight of charities had a role in the university’s unnecessary demise.

Blake Bromley

Early fundraising for Quest was handled by Blake Bromley, a retired Vancouver lawyer who specialized in tax planning. Over his 30-year career, Bromley set up 650 charities that processed approximately $2 billion in donations, he says. Bromley was also a director/trustee of Quest from 2003 until 2011.  This means that Bromley had fiduciary duty towards the university during its early years.

Since last summer, CRA has revoked the charitable status of 17 charities set up by Bromley. Lifting the lid on secrets kept for more than 20 years, the CRA audits confirm the conclusion of a 2018 investigation by The Globe & Mail which found that Bromley's charity network helped wealthy donors get big tax breaks - and their donations back.

The timeline on these audits is appalling.

On average, there was a delay of ten years between the audited transactions and revocation.

In the case of HSEF Renaissance Academy (HSEF), the delay was 21 years between a discredited, $30-million donation towards Quest and revocation as of November 19, 2022.

CRA's audit report on HSEF was sent to its directors on October 25, 2018, one day after The Globe's investigation was published. Coincidence? Hmmm ....

In the case of the Association for the Advancement of Scholarship (AAS), the CRA audit was completed in 2012. The notice of intent to revoke was sent to AAS in 2013 but then it took ten years before the charitable status of AAS was revoked as of March 25, 2023.

Bromley disputes CRA rulings, calling them "unfortunate and unjustified,” according to Dan Fumano who reported on the revocations for The Vancouver Sun.

Stewart Blusson & Archon Minerals Ltd.

According to CRA, 12 charities set up by Bromley were involved in transactions with Archon Minerals Ltd. owned by Stewart Blusson. Six of the 12 have been revoked (HSEF, AAS, Howe Sound Samaritans, Homestead on the Hill,  Headwaters and Theanon).

A geologist by training, Blusson was inducted into the Mining Hall of Fame for his role in the discovery of Canadian diamonds and a presumed $100 million donation towards Quest. CRA audits, however, tell a dramatically different story about Blusson's philanthropy.

CRA found that HSEF gave Blusson an official donation receipt for $30 million on New Years Eve of 2001. That was Blusson’s initial gift towards Quest. But not until 21 years later did CRA determine that Blusson’s gift wasn’t true.

A true gift does not result in any benefit or advantage to the donor. When a gift flows back to the donor, it's not a true gift.

CRA auditors found that eight days after Blusson got a tax receipt for $30 million, he signed an agreement to get back his Archon shares - but without paying cash to buy them back. On July 1 2005, that's what happened. Blusson's shares were returned to him as part of a "Debt Offset Agreement" between Blusson and HSEF. As part of this agreement, HSEF was to purchase a $31.3 million royalty interest, the promise of future revenue from Blusson’s diamond mine. But HSEF didn't pay cash to purchase the royalty interest from Blusson. Instead, in what CRA called "a wash," HSEF and Blusson traded the royalty agreement for the Archon shares. Then, in the final step of this series of transactions that spanned five years, on August 17 2005, HSEF donated the $31.3 million royalty agreement to Blusson's private foundation which subsequently wrote it off entirely. In fact, Blusson’s foundation wrote off $205 million.

An important point to note is that CRA found no independent appraisal for the value of the royalty interest, raising doubt as to its fair market value. 

All in all, Blusson got a tax-receipt for $30 million without making a true gift. That's not all. On September 9, 2005, just 23 days after he got back his purported donation to Quest, Blusson was invested into the Order of Canada. 

In terms of revenue from donations, Stewart & Marilyn Blusson Foundation issued tax receipts for $123 million but gave away only $342,200 to charities that are not part of the Bromley network.

AAS, another charity set up by Bromley, was also involved in the start-up of Quest. As of March 25, 2023, AAS was revoked over a second donation of shares for which a tax receipt was issued, also for $30 million. Again, CRA found that the shares were sold to purchase a royalty agreement and again, CRA found no proper appraisal. 

The revocation of AAS raises a series of questions that I put to Mr. Bromley in a letter, April 18, 2023. In particular, I asked why AAS made gifts to Bromley's charities for $16.3 million (including $12.1 million gifted to CHIMP, run by Bromley's sons), meanwhile Quest was allowed to sink into deep debt, put into foreclosure and sold.

$425 Million in Tax-Receipted Donations

By my detailed analysis of tax returns and financial statements going back 20 years, the start-up of Quest was financed by ten charities that reported a combined, total of $425 million in tax-receipted donations. All ten charities were registered by Bromley's office, according to their applications for registration. Funding Quest was officially stated as the purpose of only four of these charities (Sea to Sky, QUCF, HSEF & AAS) but for all ten, by my analysis, Quest was their sole or major focus. Of the ten, only two remain active:

In short, virtually nothing remains of the $425 million.

How Quest Was Sold

Quest opened debt-free in 2007 but with no endowment so the university took loans from a daisy chain of Bromley charities: Global Charity Fund, Foundation for Public Good,  CHIMP and finally, Vanchorverve Foundation.

By 2019, Quest’s debt had soared to to $19 million. At 7 percent, interest accrued for as much as $4,793 per day, a total of $8 million. That's charity? Sounds more like loan-sharking to me.

Unable to pay when its mortgage loan from Vanchorverve came due, Quest went into creditor protection and was sold, resulting in payment of $25 million to Vanchorverve.

During the proceedings, I filed an affidavit and testified, urging the court to pause Quest’s sale and ask CRA to investigate.

Justice Shelley Fitzpatrick, who officiated, asked me whether any CRA investigation was underway. "Are they even looking at it?" she asked.

"I can't answer that question,” I replied. The privacy restrictions of the Income Tax Act disallow CRA from providing any information to the public about a charity under audit.

As for my request that the court postpone payment to Vanchorverve and give CRA the chance to investigate, Justice Fitzpatrick said no,  "... nothing is apparently even under way at this time, as far as I'm aware," she said. But not only CRA audits were underway, three had been completed (HSEF, AAS & Howe Sound Samaritans). One was finalized in 2012, eight years earlier, and two were completed in October of 2018, more than two years earlier.

How different the fate of a promising university might have been if only the $100 million donation from Stewart Blusson had been true and CRA hadn’t taken 21 years to reveal the truth.

Posted at 01:52 AM | | Comments (0)

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04/11/2023

The Bromley Charities: Tax Returns, Financial Statements & Other Documents

Key Information:

  1. Almoner Foundation
  2. Association for the Advancement of Scholarship
  3. C&R Foundation
  4. Charitable Impact Foundation (CHIMP)
  5. Eden Glen Foundation
  6. Foundation for Public Good
  7. Fortius Foundation 
  8. Glen Lamond Foundation
  9. Global Charity Fund
  10. Homestead on the Hill Foundation
  11. Howe Sound Samaritans Foundation
  12. HSEF Renaissance Academy
  13.  QUC Residents Housing Foundation
  14.  Quest University Canada Foundation 
  15.  Sea to Sky Foundation
  16.  Steward's Charitable Foundation
  17. Stewart & Marilyn Blusson Foundation
  18.  Theanon Charitable Foundation
  19.  Timothy Foundation
  20.  Vanchorverve (Paradigm) Foundation

Key mortgage documents:

  1. Sea to Sky 614046 BC Ltd $3M (2001) 614046 B.C. Ltd. Greg Kerfoot
  2. Covenant with District Squamish (2002)
  3. Sea to Sky Blusson Foundation $10M (2004)
  4. Parcel A transfer to Blusson Foundation $1 (2008)
  5. Foundation for Public Good $20M (2014)
  6. Quest mortgage loan transferred to CHIMP (2016)
  7. CHIMP $10M (2016)
  8. Global Charity Fund transfer to Eden Glen Foundaton $1 2Feb2016
  9. CHIMP transfer to Vanchorverve $20.7M (2018)
  10. Sea to Sky Foundation $75M (2006)
  11. Stewart Blusson $65M (2012)
  12. Pacific Coastal Financial Corp. $1M (2017)
  13. BHP Billiton Diamonds $20M (2009)
  14. Dominion Diamond Mines $40M (2019)
  15. Dominion Diamond Mines mortgage discharged (2021)

Other documents:

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Vivian Krause
Vivian Krause

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