Document 11: Tax Receipting: Issuance, Responsibility, and the Issuer-of-Record Firewall
Plain-language summary: Relae can generate official CRA donation receipts for your charity. The most important rule: your charity is always the issuer of record, on your own CRA business number, and you are responsible for the judgments behind each receipt (is this gift eligible, what is it worth, what advantage was received). Relae is the tooling that produces the receipt, and we stand behind what the tooling mechanically controls. Receipt issuance only operates for your organization after you have expressly authorized it.
1. The charity is the issuer of record
All official donation receipts are issued by the Customer charity, in its own name and under its own CRA registered business number. The Customer is, and remains, the issuer of record and is solely responsible for compliance with the Income Tax Act (Canada) and the requirements and published guidance of the Canada Revenue Agency. Relae provides receipt-generation tooling; it is not a co-issuer, agent, or adviser, and no receipt is issued in Relae's name. Receipt issuance is available only to organizations that are registered charities entitled to issue official donation receipts.
2. Per-organization enablement
Receipt issuance operates for an organization only after that organization has expressly authorized it through the dedicated enablement setting, confirming that it is a registered charity, that its business number and required details are correct, and that it accepts the allocation of responsibility in this document. Until an organization enables issuance, the Platform does not issue receipts for it. Relae may condition general availability of issuance on the completion of its compliance verification of the receipting tooling.
3. What the tooling does, and what Relae stands behind
Where issuance is enabled, the Platform generates official donation receipts designed to contain the content the Income Tax Act and CRA guidance prescribe, including: the charity's name, address, and registered business number; a unique sequential receipt number; the donor's name; the date of the gift and of issuance; the amount of the gift; where applicable, the amount of any advantage and the eligible amount, including split-receipting; fair-market-value handling for gifts in kind as entered by the charity; the CRA name and website reference; and a signature field for the charity's authorized individual. The Platform retains duplicate copies of issued receipts while the Customer's subscription is active and supports export of those duplicates; the charity is responsible for retaining duplicates for the statutory period, and its export is how it meets that obligation after leaving the Platform. Relae warrants that the receipting tooling is designed to produce receipts containing these prescribed elements, to number receipts uniquely and sequentially, to compute the eligible amount correctly from the values the charity has determined and entered, and to retain duplicates as described. This warranty is about the mechanical operation of the tooling; it is not a warranty that any particular receipt complies with CRA requirements, because compliance also depends on the charity's own determinations.
4. What remains the charity's responsibility
The Customer is solely responsible for the determinations on which each receipt depends: whether a transfer is an eligible gift; valuation, including fair market value for gifts in kind; the advantage rules and the inputs to the eligible-amount calculation; donor identity and eligibility; the decision to issue, correct, replace, or cancel a receipt; the authorized signature; timing of issuance; and record-keeping and retention beyond the duplicates the Platform holds. This responsibility applies notwithstanding any workflow, validation, warning, suggestion, checklist, template, calculation, or generated output the Platform provides; those are aids to the charity's own compliance process, not a transfer of it to Relae.
5. The Customer's issuance covenant
Because the charity is the issuer of record, the Customer acknowledges and agrees that: (a) it will ensure the determinations and values it enters are correct before issuance; (b) it will designate an authorized individual responsible for its receipts and review its receipting configuration and outputs on a regular basis and at least before each year-end issuance cycle; and (c) it exercises its own independent judgment as issuer of record and does not rely on the Platform as a substitute for that judgment or for professional advice. Relae does not provide tax or legal advice.
6. Allocation of liability
To the fullest extent permitted by law, Relae is not liable for the Customer's receipting determinations or decisions, or for any CRA assessment, penalty, interest, loss of charitable status, or revocation arising from them, and the Customer will indemnify Relae against third-party claims arising from its receipting determinations and decisions; notwithstanding the liability cap in the Master Subscription Agreement, this indemnity is not reduced by that cap. Conversely, this clause does not shield Relae from liability for a failure of the tooling itself against the warranty in section 3, such as a defect that omits a prescribed element, breaks numbering, miscomputes the eligible amount from correctly entered values, or corrupts the underlying giving records; that liability remains governed by the Master Subscription Agreement. Relae's first obligation for a breach of the warranty in section 3 is to correct the defect and, at no charge, regenerate or assist the charity in issuing corrected or replacement receipts; any monetary liability for such a breach remains subject to the limitation of liability in the Master Subscription Agreement.