THE HEIR One revocation · 178 funders · one new home

The Succession

The Channel ended on a question it could not answer from its own five years of data: after CRA revokes a charity, do the charities that funded it move to one particular new organisation more than they move anywhere else? Twenty-five years of CRA releases answer it. When Beth Oloth Charitable Organization was revoked in January 2019, 115 of the 178 registered charities that had funded it began funding one foundation within two years — a foundation that had reported $406 in assets for years. Scored against every comparable collapse in the country, nothing else comes close. The Act guards a revoked charity's assets and its directors. It has no rule about its donors.

115/178

Funders who followed to one heir

1st

Of 24 collapses with 50+ funders · median 12%

$378.1M

Sent abroad by the heir, 2019–2024

$705,754

Reported as gifts to Beth Oloth after it stopped being a charity

The study it starts from

Three charities, one pattern, no control group

In 2022 Miles Howe and Paul Sylvestre, writing in the Journal of White Collar and Corporate Crime, tracked three Toronto charities across twenty years of CRA data and called the pattern a “burner charity”: a dormant registration activated, run at scale, revoked, and replaced by the next one, with the same funders moving each time.

A grey registry folder bound shut with a red seal. — REVOCATION

What the record established before this page

CRA's own findings

Beth Oloth was revoked effective 12 January 2019 and Gates of Mercy effective 13 April 2019, each by notice in the Canada Gazette. CRA's case against Beth Oloth, released in a 94-page letter, cited a “lack of direction and control” over money sent to non-qualified donees, support for Israel's armed forces through pre-army academies, about $1.2 million to projects in the occupied territories, and inadequate books and records. Neither charity appealed, the study reports.

What the study could not show

That the funders' movement was unusual. It picked its “anchor foundations” because they gave across all three charities, then cited that consistency as the evidence. It never asked how often funders move together after any collapse. That is the test The Channel listed as its sixth unfinished join.

SOURCES · CANADA GAZETTE PART I, 12 JAN 2019 & 13 APR 2019 · THE CJN, 29 JAN 2019 · HOWE & SYLVESTRE (2022)

Their tables, checked cell by cell against the T3010

Revenue, expenditures and money sent abroad: 53 of 54 cells match CRA lines 4700, 5100 and 200 to the dollar.
The one that does not: Beth Oloth, 2015 expenditures: the paper prints $42,972,707; the return says $42,950,183.
The figure the study called inexplicable: The study found the third charity's 2019 foundation gifts larger than its 2019 revenue. That is a calendar, not a mystery: its fiscal year ends on 31 May, most donors close theirs in December, so a donor's “2019” is mostly the recipient's 2020.

The study's numbers are sound. Its headline was not: the “$400 million” it called unlawful includes the third charity, which it also wrote it “cannot conclusively” call a conduit. This page publishes only what the returns show.

Two desk calendars side by side, one year marked in navy, the other in red, the blocks out of step. — FISCAL CALENDARS

Howe & Sylvestre, 2022, CC BY-NC 4.0 Gazette, 12 Jan 2019 Gazette, 13 Apr 2019 The CJN

Three registrations, one audience

The money arrived in turns

What each charity received from other registered charities, year by year, read from the donors' returns — so a charity that stopped filing still shows up. One scale across all three panels. Tap or hover a bar for the year.

Three white registry boxes on a dark shelf, two closed with red ribbon, the third open and filling. — THREE REGISTRATIONS

Gates of Mercypeak $9.5M in 2017

Beth Oloth Charitable Organizationpeak $28.0M in 2017

Moral Arc Foundationpeak $53.5M in 2023

Show the numbers as a table

Gifts received from registered charities, read from the donors' own returns (T1236)
Year	Gates of Mercy $	donors	Beth Oloth $	donors	Moral Arc $	donors
2003	$7,500	2	—	—	$452	3
2004	$85,932	6	—	—	—	—
2005	$349,924	8	—	—	—	—
2006	$544,009	15	$180	1	—	—
2007	$486,286	20	$5,360	2	—	—
2008	$2,669,924	80	$7,620	22	$26,500	3
2009	$5,014,902	93	—	—	$22,272	3
2010	$7,472,248	132	$2,000	2	$6,000	3
2011	CRA published no qualified-donee file for 2011
2012	$6,152,362	145	$6,036,051	104	$27,460	8
2013	$3,156,175	62	$14,114,784	166	$5,250	2
2014	$2,070,930	33	$19,325,137	179	$140,895	16
2015	$197,673	25	$16,961,960	169	$130,390	2
2016	$8,076,748	26	$20,383,587	172	$502,945	3
2017	$9,494,608	24	$28,028,748	186	$215,290	3
2018	$7,268,929	30	$27,519,993	202	$84,843	6
2019	$6,491,609	34	$5,918,525	76	$27,014,747	157
2020	—	—	$75,763	4	$30,666,542	175
2021	$1,000	1	$228,535	2	$34,541,897	187
2022	$1,000	1	$315,457	4	$50,402,308	202
2023	$4,500	1	$65,186	2	$53,524,110	224
2024	$3,500	1	—	—	$53,447,421	224

CRA qualified-donee files (T1236), releases 2003–2024Hatched: 2011, a year CRA published no gift file forThe third registration was named Jewish Heritage Foundation of Canada until CRA's 2017 release

The reading of the funder list

Every collapse in the country, scored the same way

The rule was fixed before the named charities were looked up, then run over all 2000–2024 of CRA's gift files. A collapse is any charity that had been receiving at least $1 million a year from other charities and then lost at least half of it over the next two years. Its funders are the charities that gave it $5,000 or more in the two years before. A funder follows when it starts giving to a recipient it had not given to in the previous four years.

Sheets lifting out of a ribboned box and arcing into an open file box beside it. — THE HANDOFF

Beth Oloth, 2019

The named case

Funders before the revocation: 178
Began funding Moral Arc Foundation within two years: 115 · 64.6%
The next most popular new recipient among the same funders: 20 funders
Given to Moral Arc by those funders in those two years: $54.0M

FIRST OF 24 · 5.8× THE RUNNER-UP

Every other collapse

The control

Collapses scored, all sizes: 345
With 50 or more funders: 24 · median share 12.3% · 90th percentile 30.9%
Largest move to one recipient anywhere else: 32 funders, out of 256
Typical heir against its runner-up: 1.33×

WHAT A COLLAPSE NORMALLY LOOKS LIKE

The ranking holds at every size cut tested: first of 69 collapses with 30+ funders, first of 7 with 100+.

What a common cause looks like

The other way funders move together

Coordination is not the only thing that sends many funders to one place. A shared outside event does it too, and the data shows exactly what that looks like.

Rows of index-card trays, each card tabbed in gold. — FUNDER LIST

2021–2022: Canada-Ukraine Foundation

The shape

It was the top new recipient for the funders of 22 unrelated collapses in the same window — a United Way, a university, a food bank network, a children's hospital foundation. Funders everywhere gave to Ukraine relief. The largest single move was 17 funders.

The difference

A common cause pulls a few funders each out of many charities. The Beth Oloth move pulled 115 funders out of one. Moral Arc was also the top new recipient for 4 smaller collapses in the same years, at 4 to 6 funders each — the shape of a common cause, around one charity.

A PATTERN IS ONLY A FINDING ONCE YOU KNOW WHAT THE BASELINE LOOKS LIKE

The first handoff

Gates of Mercy to Beth Oloth: visible, and not rankable

The study's first succession is real in the returns. It cannot be put through the same test, for two reasons the page will not paper over.

A shelf of identical binders with one dashed gap where a year should be. — MISSING YEAR

What the returns show

Charities that funded Gates of Mercy, 2008–2010: 104
Charities that began funding Beth Oloth, 2012–2013: 95
On both lists: 58 · 61% of Beth Oloth's new funders, $7.4M of its $16.2M in new money

It is not a collapse. Gates of Mercy kept operating, and kept receiving millions, until 2019; its funders moved while it was still open. And the move runs straight through 2011, the one year CRA's open release has no gift file for, so “new in 2012” cannot be told apart from “started in 2011”. Reported as a description, not ranked.

The family accounts

They paid each other, and said so on their own returns

Every row below is a gift one of the three charities reported giving to another, on its own qualified-donee schedule.

Three clear trays of filed cards, a few tabs in navy among the gold. — BOARD RECORDS

Gifts among the three registrations, as reported by the giver
Year	Giver	Receiver	Amount
2010	Gates of Mercy	Moral Arc Foundation	$2,000
2012	Beth Oloth Charitable Organization	Moral Arc Foundation	$360
2012	Beth Oloth Charitable Organization	Gates of Mercy	$73,000
2012	Gates of Mercy	Beth Oloth Charitable Organization	$600,136
2013	Beth Oloth Charitable Organization	Gates of Mercy	$3,000
2013	Gates of Mercy	Beth Oloth Charitable Organization	$240,000
2014	Gates of Mercy	Beth Oloth Charitable Organization	$155,000
2015	Beth Oloth Charitable Organization	Gates of Mercy	$50,000
2015	Gates of Mercy	Beth Oloth Charitable Organization	$60,000
2016	Beth Oloth Charitable Organization	Gates of Mercy	$25,000
2016	Gates of Mercy	Beth Oloth Charitable Organization	$30,000
2017	Beth Oloth Charitable Organization	Gates of Mercy	$50,000
2017	Gates of Mercy	Beth Oloth Charitable Organization	$245,883
2018	Gates of Mercy	Beth Oloth Charitable Organization	$340,000
2019	Moral Arc Foundation	Gates of Mercy	$2,710,300

Totals and boards

Gates of Mercy to Beth Oloth, 2012–2018: $1,671,019 · and $201,000 the other way
Moral Arc to Gates of Mercy, fiscal year ending 31 May 2019: $2,710,300 — the fiscal year in which Gates of Mercy was revoked
People on more than one of the three boards, 2000–2024: 4
On all three: One director: Beth Oloth 2009–2011, Gates of Mercy 2009–2018, the future Moral Arc 2010–2017
Names on Moral Arc's board from the 2018 release on that appear on either other board: 0

Since 2003, when the return began asking, 159 of 166 director-years across the three boards are flagged “at arm's length” — including every year one person sat on all three. The exception is Moral Arc Foundation's 2011 return, which marks all 3 of its directors as not. The boards separated before the funders arrived. 92 of Moral Arc's 126 new funders in 2019–2020 had funded Beth Oloth in 2017–2018, and they brought 89% of its new money. 76 charities funded all three registrations.

Gifts to a registration that no longer existed

$705,754 to Beth Oloth after the Gazette

A revoked charity is no longer a qualified donee. Gifts to it kept appearing on other charities' returns anyway.

An open register of rows beside three loose gift slips tabbed in gold. — REPORTED GIFTS

The schedule has a recipient, an amount, and no date

Placeable

Fiscal years that began after 12 January 2019: 12 returns from 8 charities report $705,754 to Beth Oloth, the last for a year ending 2023-12-31. Two charities account for nearly all of it, year after year. Gates of Mercy: $10,000, from one charity.

Not placeable

Fiscal years that straddle the revocation: 76 returns, $5.9M to Beth Oloth; 33 returns, $6.5M to Gates of Mercy. A gift on 2 January and a gift on 2 December are the same row.

THE FORM KNOWS THE RECIPIENT'S NUMBER · IT IS NEVER CHECKED AGAINST THE REGISTER

The donee's registration number sits on the row. The register of revoked charities is public. Matching one against the other at filing time would have flagged every placeable row. The file also carries negative “gifts” to Beth Oloth, which no form should accept.

The will

The Act guards the estate and the executors. Not the mourners.

When a charity is revoked, the Income Tax Act follows three things out of it. Read the provisions in a row and the gap is plain.

An open statute book marked with a red and a gold ribbon. — THE STATUTE

The assets — s.188

A revoked charity owes a revocation tax equal to what it holds, plus what it takes in while winding up, less debts, its own charitable spending, and transfers to an “eligible donee”. An eligible donee must have more than half its board at arm's length from the revoked charity's board (s.188(1.3)). The Act foresaw a related successor — for the property.

At its last return: Beth Oloth $1,169,543 in assets (2017-09-30) · Gates of Mercy $196,894 against $287,211 in liabilities (2018-08-31)
The people — s.149.1(1) and (4.1)(e)

A director who served while a charity “engaged in conduct that can reasonably be considered to have constituted a serious breach”, and was revoked for it, is an “ineligible individual” for five years. A charity with one on its board, or controlled or managed by one, can be revoked.

Moral Arc's board, from the 2018 release on: no name in common with either revoked charity
Gifts between charities — s.149.1(4.1)(a) and (b)

A gift between charities whose purpose is “to avoid or unduly delay the expenditure of amounts on charitable activities” is a ground for revocation, for both sides. It is written against parking money, not against moving it.

Aimed at delay, not at destination
The funders — nothing

No provision addresses where a revoked charity's donors give next. A pass-through charity holds almost nothing, so the asset rule bites on almost nothing. Its directors can step off a board years before the revocation. What it actually has is its funder list, and the funder list walks.

The one asset of a conduit is the one thing the Act does not follow

ITA s.188 ITA s.149.1Consolidated text, read 23 October 2026

The heir, six years on

$447.1M in, $378.1M out, in six years

Moral Arc Foundation is a registered public foundation, listed in CRA's 2024 release. CRA has published no finding against it. These are its own returns since the funders arrived.

One white file standing alone on an empty steel shelf. — DORMANT FILE

Moral Arc Foundation (BN 118974294RR0001), T3010 as filed
Fiscal year ending 31 May	Revenue (4700)	Spent outside Canada (200)	Management & admin share
2019	$21,145,207	$14,543,352	0.28%
2020	$65,756,325	$56,025,404	0.22%
2021	$63,214,904	$53,484,687	0.37%
2022	$87,018,658	$70,956,962	0.3%
2023	$99,403,332	$87,679,589	0.24%
2024	$110,556,257	$95,374,900	—

Scale against the two it followed

Sent outside Canada, line 200: Gates of Mercy $85.0M · Beth Oloth $194.4M · Moral Arc $378.1M
Intermediaries itemised on its 2024 return: 743 · Israel 52.0% · United States 46.9% of the amount
Before 2019: Total assets of $406, return after return

Nearly twice what Beth Oloth moved in its whole life, in six fiscal years, with management and administration at a fraction of one percent. Whether that spending is under the “direction and control” the Act requires is a question only an audit answers. What the public file shows is that the audience inherited the stage.

A test we built and dropped

The mirror test made everything look like a handoff

The obvious second test runs the logic backwards. It failed, and why it failed is the most likely mistake for anyone repeating this.

The test that looked right

“For every charity whose funding surged from nothing to millions, find the one charity whose funder list supplied most of its new funders.”

It ran over 23 surges. The median surge scored 59%: more than half of almost any new charity's funders already gave to some large, popular charity — a university, the Salvation Army, a hospital foundation — so every surge appeared to have a “source”. A test that convicts the median is not a test.

It also could not score the named charities at all: their surges sit next to the missing 2011 file, or follow years of small receipts. Dropped. The collapse test above survives because it starts from one charity's own funders and asks where they went, which a popular bystander cannot fake.

What would close it

Five joins, and what each one needs

Every field below already exists in a file CRA publishes.

Flag the heir

When a revoked charity's funders move, in numbers, to one recipient, review the recipient. The test on this page ran in under three minutes over every gift file CRA has published.

Needs a join CRA can already run — the code is linked below
Check the donee against the register at filing

The qualified-donee schedule carries the recipient's registration number. Refuse a gift row whose number belongs to a revoked charity, and refuse a negative gift outright.

Needs a validation rule at submission
Date the gift

A schedule with no date cannot say whether a gift was made before or after a revocation. One field ends the straddle.

Needs one column on T1236
Publish the missing year

The 2011 release has identification, financial and director files, and no gift file. It is the year a succession in this record passed through.

Needs a file CRA holds
Read the funder list the way the Act reads the board

s.188(1.3) already asks whether the receiving charity's board is at arm's length from the revoked one. The same question can be asked of the receiving charity's funders.

Needs a policy decision — the only one of the five that does

What this is not

The claims this page refuses to make

Each is within reach of the data above. None follows from it.

That Moral Arc Foundation is a conduit

Supported

That it received the largest coordinated funder move in CRA's record, from the funders of a charity revoked for lack of direction and control.

Not supported

Anything about how it directs its own spending. That requires an audit. CRA has published none.

INHERITING THE AUDIENCE IS NOT INHERITING THE FINDING

That the move was planned

Supported

That it happened together, at a scale no other collapse approaches, to a registration with a shared history of boards and gifts.

Not supported

Who decided it. Intent needs a record of the decision. The public files hold the result.

A FUNCTIONAL READING · NOT A STATEMENT OF PURPOSE

That any funder broke the law

What is published

Counts of funders, and dollars, exactly as their own returns report them.

What is not

The funders' names. A gift to a registered charity is lawful; naming 115 charities on a page about a revocation would imply what the data does not show.

THE SUBJECT HERE IS THE FORM, NOT THE FILER

Method and limits

How this was built

What a machine did

Every figure on this page is computed by measure.py from CRA's annual List of charities releases, 2000–2024, and written to measure.json. The page itself is rendered from that file by render.py, so it cannot state a number the build did not produce.

The rule, as fixed

A gift counts at $5,000 or more in a year, read from the giver's qualified-donee schedule and dated by the release year of the giver's return. A collapse needs at least $1 million a year from charities before, and half of it gone over the next two years; only the first year of a collapse is scored, and only if the charity had at least ten funders. A follower is a funder that starts giving to a recipient it had not given to in the previous four years. Thresholds were set before the named charities were scored.

The missing year

CRA's 2011 release contains no qualified-donee file. A missing year looks like a collapse, and a gift made in 2011 looks like a new one in 2012, so every event whose window touches 2011 is dropped rather than filled. That is why the first succession is described, not ranked.

What a person did

Matched the Gazette notices, read the Act, and checked the study's tables. Director names are compared as written on the returns, which is the only identity the public file carries.

The data and the code

measure.json holds every figure. collapse-events.csv is all 345 scored collapses by size and share, with only the named case labelled. three-charities.csv is the three registrations' filed lines, year by year. build/README.md is the recipe.