April 6, 1997

Mr. Rheal Dorval, Assistant Director,
Auditor's Division,
Revenue Canada Charities,
400 Cumberland Street,
5th Floor,
Ottawa., Ontario,
K1A 0L5.

Dear Mr. Dorval:

        Re: Charitable Status of League for Human Rights of B'nai Brith
#0374009-49

        I am writing in regards to  the League for Human Rights of B'nai
Brith which, as I understand it, is registered as a charity and can issue
receipts for income tax purposes under the number 0374009-49. I ask that
you consider and investigate the following information with a view to
revoking the charitable status of this group.

        I wish to call your attention to a number of documents that are
enclosed.

        1. The first is a press statement dated December 11, 1996  issued
by the League for Human Rights of B'nai Brith. The press release makes a
long list of political accusations against me -- most of them untrue. the
press release concludes: "'We call on the Peel Board of Education to make
good the words of then Chairman Kent and take the necessary actions to
remove this indivcidual [Paul Fromm] from the Peel Board of Education, ...
stated Karen Mock, ... National Director of the League for Human Rgiths of
B'nai Brith.'" [Appendix A] What does meddling in the terms of employment
between an individual and a Board of Education have to do with the accepted
objects of a charity? Is trying to get a person fired for his political
views an acceptable activity of a registered charity?

        2.Next is a January 15, 1997 press release from the League for
Human Rights of B'nai Brith. Erroneously entitled "Fromm Fired From Peel
Board" -- actually my situation was then  still under consideration -- the
press release states: "The League for Human Rights of B'nai Brith Canada
has learned that Paul Fromm, a teacher with the Peel Board of Education
will have his contract terminated. ... The League provided the Board with
concrete evidence, including a video and printed material, that Fromm had
not ceased his [political] activities in this regard." [Appendix B] Does
keeping dossiers on private citizens and lobbying employers to have people
fired qualify as charitable activity within the terms of the law?

        3. A May 1, 1992 letter from Karen Mock of B'nai Brith to
then-Minister of Education Tony Silipo confirms B'nai Brith's procedure of
keeping files on citizens: "We have a long standing file on Mr. Fromm. ...
The League for Human Rights of B'nai Brith Canada urges that a full inquiry
into the Fromm matter be conducted by the Ministry of Education." [Appendix
C] Once again, this seems clear evidence of lobbying to affect public
policy.

page 2

4. Statements in a March 6, 1997 report "Peel board dismisses Fromm as
teacher" confirms the lobbying role played by B'nai Brith in trying to get
me fired. "Fromm landed in hot water after B'nai Brith Canada produced a
videotape and other evidence suggesting Fromm had violated the board's
ethnocultural policy. ... 'We commend the Peel Board .... for their
precedent-setting decision,' said Rochelle Wilner, national chair of the
B'nai Brith's League for Human Rights. Karen Mock, national director of the
League, said a coalition of groups had advocated Fromm's dismissal, ... as
did the B'nai Brith lodge in Halton Peel." (Canadian Jewish News, March 6,
1997) [Appendix D]

5. A series of pages downloaded from B'nai Brith Canada's website clearly
indicate that B'nai Brith sees itself as a political lobby group, seeking
change in legislation or the enactment of legislation or political
measures. [Appendix E]

        *  The cover page identifies B'nai Brith as "Canada's leading
Jewish advocacy ... organization"
        
        * "B'nai Brith Canada established its Government Relations Office
to liaise with Members of Parliament, civil servants and world ambassadors.
The Government Relations Office also facilitates B'nai Brith's appearance
at the Supreme Court of Canada, at Parliamentary Committees, and at
departmental  consultations." That is clearly the description of a
political lobby group, not a charity.
        
        * "The Minister of Justice tabled Criminal Code amendments which
included penalty enhancements for hate-motivated crimes. B'nai Brith Canada
was publicly credited for having initiated these proposals." Here is a
direct admission of B'nai Brith's role as a political lobby.

        * "The League intervenes as a 'friend of the court' on relevant
cases. Prosecutions in which the League has been involved include Ernst
Zundel, Jim Keegstra, John Ross Taylor, Malcolm Ross, and other alleged
Nazi War criminals." Here again the B'nai Brith explicitly describes itself
as an advocacy group pushing its own agenda. It might be noted that the
passage just quoted makes the outrageous assertion that Zundel, Keegstra,
Taylor, and Ross were war criminals. None of these men were ever charged
with that crime. Indeed, Malcolm Ross was born after World War II!

        * On the issue of alleged Nazi war criminals, B'nai Brith
emphasizes its role as an advocacy group. " For many years, B'nai Brith
Canada has taken a leading role in advocating the prosecution of alleged
war criminals in Canada. .... B'nai Brith Canada intervened in the Imre
Finta trial. ... B'nai Brith Canada has been in ongoing contact with the
Department of Justice ..., urging accelerated action on the war crimes
dossier." 

        *"Through B'nai Brith's Government Relations Office in Ottawa, the
League liaises with government officials and federal and provincial
politicians. It makes submissions on policies and legislation relevant to
Human Rights, multiculturalism and anti-Racism." It might be noted that
these are contentious political issues. Again, B'nai Brith quite clearly
identifies itself as a lobby group with a message to sell.

        From this evidence, it would appear that the League for Human
Rights of B'nai Brith is 
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engaged in political advocacy and lobbying. These activities would seem to
run contrary to Revenue Canada Circular T4063. An "organization will not
qualify for charitable registration if at least one of its purposes is
political. The courts have decided that organizations seeking to achieve
political objectives, in whole or in part, are not charities. Examples of
purposes of a political nature include: promoting a political doctrine'
persuading the public to adopt a particular view on a broad social
question; attempting to bring about or oppose changes in the law or
government policy." B'nai Brith, from its own self-description, has engaged
in all these activities.

        Should B'nai Brith contend that it is a charity because it engages
in informational work, the partisan nature of B'nai Brith's activity --
including such acts as campaigning to have a public servant like myself or
Malcolm Ross fired -- would seem to disqualify B'nai Brith as an
educational organization as defined by law. Circular T 4063 explains: "The
courts have ruled that an activity which advances education should involve
a full and fair presentation of the facts so people can draw their own
conclusions. Therefore, if an organization intends to ifluence the opinion
or actions of the public toward one side of a controversial issue, then the
organization is not advancing education in the charitable sense.  ... An
advocacy group would not qualify as a charity under this category." 

        I might say that, in regards to myself, the B'nai Brith press
statement of December 11 [Appendix A] is demonstrably filled with lies and
distortions. Just to take two examples, neither James Keegstra nor Doug
Christie were invited speakers at the Third Option for National Unity
meeting in Edmonton in October, 1996.
Equally mendacious is the statement: "March 22, 1996, Fromm organised a
'hate conference' at the Surrey Inn." Promotion of "hate" is contrary to
Section 319  of the Criminal Code of Canada. The B'nai Brith statement is
likely libellous as the organizers of this conference were never charged or
convicted of promoting hate. Thus, it can no more be called a "hate"
conference than a murderers' conference.

        From the material presented, it would clearly seem that the League
for Human Rights of B'nai Brith is a highly biased political advocacy
organization actively involved in efforts to influence legislation and the
behaviour of public bodies. As such, their activities seem to stray far
beyond the presecribed definitions of charitable activity normally
acceptable by Revenue Canada.

        I am asking that you undertake an urgent and thorough review of
B'nai Brith's status as a charity.

                                                Sincerely yours,



                                                Paul Fromm
                                                Director