The appellant, an amateur youth soccer association operating exclusively in Ontario, applied to be registered as a charity under the Income Tax Act.
The Canada Revenue Agency denied the application on the basis that promoting sport is not a charitable purpose at common law.
The Supreme Court of Canada dismissed the appeal, holding that while the specific statutory provisions for national amateur athletic associations do not preclude other sports organizations from charitable status, the promotion of sport itself is not recognized as a charitable purpose under the common law.
The Court concluded that expanding the definition of charity to include amateur sports is a matter for Parliament, not the courts.