In response to last fall’s Canada Post strike and its impact on charitable revenues, the Government of Canada announced on December 30th they would allow donors an extra two months to claim donations on their 2024 income tax returns. The new deadline for the applicability of the Charitable Donations Tax Credit (CDTC) for 2024 donations became February 28th, 2025.

The surrounding political uncertainty of events in Parliament including prorogation and the upcoming federal election have hindered smooth implementation of this extension. Many donors and charities have wondered whether the announcement would be honoured if legislation can’t be tabled – let alone passed – prior to the end of February.

The following will hopefully provide clarity for charities seeking to take advantage of this opportunity to recover from the strike. There is still a month left to benefit from the extension!

Given prorogation, is the extension currently in effect?

Yes. The CRA has confirmed that it will administer the December 30th announcement (and the associated draft legislative proposals) as if the required changes to the Income Tax Act were already passed into law. Donations delivered to charities between January 1st 2025 and February 28th 2025 are eligible for this extension.

While this CDTC extension is unusual, the government has enabled this twice in the past (though of shorter duration). In 1997, a similar postal strike led to a CDTC extension until January 31st 1998, and in 2004 the government sought to boost donations toward the tsunami relief effort with an extension to February 15th, 2005. In both cases, legislation containing the required amendment to the Income Tax Act wasn’t tabled until months after the extension deadlines had passed.

While technically the extension needs to be passed into law, the government is able to direct Canada Revenue Agency to administer changes to these kinds of rules before Parliament approves the changes retroactively. This is why you’ll see reference to “draft legislation”, or “proposed extension” in government communications about the extension.

What kinds of donations are covered?

The extension applies to donations made by individuals, corporations or trusts that are made by way of cash, credit card, cheque, money order, or electronic payment. Donations do not need to be made through mail to apply.

What kinds of donations are excluded?

This extension does not apply to donations made by payroll deduction, or donations of tangible property (such as real estate or land).

As non-cash donations are not covered, donations of publicly listed securities are not eligible for the extension. Given the need for speed and simplicity (AMT rules and capital gains inclusion/exclusion would make things complicated), securities are not covered.

Can donors choose which year, 2024 or 2025, to claim donations made during this two-month period?

Yes. Donors will be able to opt to include donations made between January 1, 2025 and February 28, 2025 when filing their tax return for 2024, or choose not to take advantage of the extension and instead claim donations made during the extension period in their 2025 tax return (or in any of the 5 following years) as they would have otherwise been entitled.

Do charities need to receipt differently?

Charities are to issue receipts as they normally would: for the date the donation is received (or in the case of mail, the date of postage). For charities that have recurring monthly donations, they may need to adjust their systems to issue a receipt for the 2024 calendar year, issue another receipt for January and March 2025 so the donor can choose to apply these for 2024, and then adapt their 2025 processing to account for the remaining 10 months of the year.

On January 23rd, CRA released guidance for donors and charities specific to the extension.

Will a donation delayed by mail still count toward a 2024 tax year?

Those who were worried that mail-based donations sent during the strike and stuck in transit would not be eligible for the 2024 tax year are hopefully comforted by the extension, since any backlogs are likely to be resolved by March 1st. At any rate, the postage stamp date on the envelope is considered by CRA to be the date the donation was made. So, donors should aim to put their donations in the mail prior to February 28th, and charities may need to send remaining 2024 receipts at least a week into March.

Hopefully these answers bring some clarity to donors and the charities seeking to recover some of the deep losses incurred during the postal strike. 

For detailed questions specific to your context, CRA will provide guidance on the extension details and can be reached at 1-800-267-2384. Individual donors can call 1-800-959-8281. Charities can also reach out to us at publicpolicy@imaginecanada.ca.

• Initial government announcement: Government of Canada announces extension of 2024 charitable donations to February 28, 2025
• CRA confirming the extension will be administered despite prorogation: Clarifying the CRA’s approach in administering the proposed tax measure…
• CRA guidance for charities specific to the extension: Extension of 2024 charitable donations - Canada.ca
• CRA guidance on receipting: Issuing receipts - Canada.ca