Under Layered Suspicion

A Review of CRA Audits of Muslim-led Charities

Under Layered Suspicion identifies whole-of-government policies and patterns of audit practices that together demonstrate potential biases in Canada Revenue Agency (CRA) audits of Muslim-led charities.

Muslim-led charities have for years expressed concerns about the selection, frequency, and reasoning behind audits of their organizations.  

The findings from Under Layered Suspicion suggest that there is a basis for these concerns. The report draws attention to the Government of Canada’s approach to anti-terrorism financing and anti-radicalization, and the legitimate concerns of bias embedded within their framing. When operationalized by the CRA, these policies seem to make Muslim-led charities exceptionally vulnerable to audits, or worse, revocation of charitable status.  

The targeting of Muslim-led charities not only undermines the critical work these organizations do to combat racism and discrimination in society, but also calls into question Canada’s commitment to inclusive multiculturalism.  

This research reveals the need for a formal commitment and concentrated effort by the Government of Canada to investigate patterns of bias within the machinery of its agencies and bureaucracies.

The Government of Canada's

"Risk-Based Assessment"

model associates:


of all terrorist financing risk with racial minority communities


of all terrorist financing risk with identifiably Muslim organizations


Under Layered Suspicion uncovers suspicious patterns of potential structural biases and policies that influence the selection of Muslim-led charities for audit, the practices within those audits, and their findings.

Structural bias

Othering Muslims

A bias that casts Muslims, and their lifestyles and activities, as inherently foreign or outsider. It makes the idea of a ‘domestic Canadian Muslim’ questionable.
How this structural bias can affect audits:

This bias enables suspicions that Canadian Muslim-led charities serve foreign interests.

How this structural bias can impact Muslim-led charities:

Ascribes a negative, or threatening, foreignness to Muslims, which creates more barriers for charities that promote inclusion and the civic participation for Muslims in Canadian society.

Structural Bias

Formatting Religion

A bias that makes it hard to label as “religious” any activity that is not formatted along Christian ideals and practice.
How this structural bias can affect audits:

This bias can impose a burden on non-Christian minority religious groups that organize themselves through charitable organizations.

How this structural bias can impact Muslim-led charities:

This bias has the potential to create suspicion about the ways Muslim-led charities advance their religion for purposes of charities law in Canada.


Anti-Terrorism Financing

A whole-of-government policy that can be used to suspect Muslim-led charities as especially vulnerable to terrorist financing.
How this policy can affect audits:

This policy can unduly inform which organizations the CRA audits under the cover of national security and anti-terrorism financing, and how information obtained during the audit process is interpreted and operationalized.

How this policy can impact Muslim-led charities:

This policy can further securitize Canada’s Muslim minorities, which may lead to more extensive reviews of Muslim-led charities.



A whole-of-government policy that looks for, anticipates, and prevents radicalization and extremist violence before it happens.
How this policy can affect audits:

This policy can bias audits based on little more than stereotypes about race, religion and proclivities to violence.

How this policy can impact Muslim-led charities:

Canada's national security regime can bear down particularly on Muslim-led charities, whose constituents are suspected of holding or espousing conservative views.

Case Studies

The questions that emerge from the review of the audit record of three Muslim-led charities are summarized below, and expanded upon in detail within the report.

While these case studies are not statistically representative of all Muslim-led charities, they provide insight into how Muslim-led charities can get caught in the web of potential biases and policies that the CRA enacts.

Case 1

Ottawa Islamic Centre and Assalam Mosque

Suspicions within the Audit:

The Ottawa Islamic Centre lost its charitable status for non-compliance with the Income Tax Act, but was suspected of violating the ‘public benefit’ because of the possibility that its invited speakers’ presumed, not substantiated, speeches may have promoted radicalization.

Questions that emerge from reviewing the audit:
  • How does the CRA understand what kind of speech is or isn’t of public benefit?
  • Who can espouse conservative ideas freely, and whose conservative ideas attract the label of radicalization?

Case 2

The Islamic Shia Assembly of Canada (ISAC)

Suspicions within the Audit:

The Islamic Shi’a Assembly of Canada (ISAC) was suspected of having ties to Iran and financing terrorism.

Questions that emerge from reviewing the audit:
  • How do we understand and regulate religions that do not fit the Common Law framing of “advancing religion”, which draws upon a Christian understanding of religion?
  • To what extent do changing multilateral diplomatic relations influence the timing, targeting, and interpretive lens of domestic audits?

Case 3

International Relief Fund for the Afflicted and Needy-Canada (IRFAN-Canada)

Suspicions within the Audit:

IRFAN-Canada was suspected of having links to Hamas in Palestine.

Questions that emerge from reviewing the audit:
  • To what extent do domestic political debates about complex global affairs influence the timing, targeting, and interpretive lens of domestic audits?
  • How does the CRA ensure the evidence it uses does not enable or perpetuate dominant and reductive stereotypes that link Muslims, Arabs, and Islam to terrorism?

Read the Full Report

Under Layered Suspicion is a story of three organizations that were audited by the CRA. The three case studies offer a narrative about the impact of Canada’s whole-of-government approach to anti-terrorism financing and anti-radicalization on Muslim-led charities. The analysis raises questions about how and why the CRA selected the evidence it did, and adopted the interpretations it did in the course of the audits.

The report gestures to a series of recommendations, including further study and examination across a broader cross section of charitable organizations in Canada, to explore, confirm, or otherwise explain what is identified as suspect practices.

View Report
The cover of the "Under Layered Suspicion" report

Professor Anver M. Emon, co-author of the report, goes through each section and provides key details and findings from the research.



to the Canada revenue Agency

  1. Suspend the Review and Analysis Division (RAD) pending review of Canada’s Risk-Based Assessment (RBA) model and its National Strategy to combat extremism and radicalization.
  2. Suspend discretionary use of revocation power in audits of Muslim-led Charities where anti-terrorism financing or counter-radicalization policies inform the audit.
  3. Enhance transparency between the CRA’s Charities Directorate and charities audited under suspicion of terrorism financing and/or radicalization.

to Finance Canada

Review and revise Canada’s risk-based assessment of terrorism financing in Canada.

To Public Safety

Provide greater guidance to government officers on how its counter-radicalization strategy is to be applied in a non-discriminatory fashion.


View news and updates related to Under Layered Suspicion.

The Philanthropist Journal

September 21, 2021

The Philanthropist covers the report in detail and the impact of CRA's audit approaches to diverse populations served by the non-profit sector.

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Ontario Non-Profit Network

August 19, 2021

ONN references Layered Suspicion as part of their call on federal government to enforce Income Tax Act in non-discriminatory ways.

Read More

Tax Notes

July 26, 2021

Prof Anver Emon responds to Canadian Gov't intention to examine systemic biases in audits of Muslim-led Charities.

Read More

Global News

July 22, 2021

The report and Prof Anver Emon featured in Global news segment ahead of Islamophobia summit.


The Globe & Mail

July 20, 2021

Prof Anver Emon and Dr. Nadia Hasan op-ed on Gov't own involvement in systemic biases towards Muslims.

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Middle East Eye

July 6, 2021

Faisal Kutty outlines research that indicates unfair targeting of Muslim-led Charities by the CRA.

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Toronto Star, Opinion

July 2, 2021

John Packer writes about need to remove systemic biases in Gov't targeting of Muslim-led charities.

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Hamilton Spectator

June 29, 2021

Matthew Greene outlines the opportunity for Gov't to stop unfair targeting of Muslim-led charities at upcoming summit.

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Hill Times

June 23, 2021

Abdul Nakua echoes call for Canadian Government to suspend its discriminatory practices towards Muslim-led charities, in wake of new research reports.

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Ottawa Citizen

June 15, 2021

Monia Mazigh writes about the deep roots of Islamophobia that take place in policy.

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June 10, 2021

Professor Anver Emon featured on CityNews to support growing research findings about systemic biases in CRA audits of Muslim-led charities.

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Accountancy Insurance

May 18, 2021

"... findings indicated that there may be biases in how the government has been undertaking audits of Muslim charities in the country."

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Winnipeg Free Press

May 10, 2021

Co-author, Nadia Hasan, discusses questions report raises about how CRA conducts audits of Muslim-led charities.

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Canadian Lawyer

May 7, 2021

Faisal Kutty, a Canadian legal academic, summarizes key findings of "Under Layered Suspicion".

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Hilborn Charity eNews

May 5, 2021

Ann Rosenfield, the Editor of Hilborn Charity eNews, reinforces the importance of fair treatment to charitable sector.

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Faculty of Arts & Science

April 29, 2021

Press release by Faculty of Arts & Science on "Under Layered Suspicion".

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Institute of Islamic Studies

April 29, 2021

The Institute of Islamic Studies' response to Federal Budget 2021's anti-terrorism financing measures.

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Hilborn Charity eNews

April 27, 2021

Hilborn Charity distributes summary of the report.

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Hill Times

April 12, 2021

Dr. Mohammed Iqbal Alnadvi writes about need for CRA to better define its mandate and guidelines.

Read More

Imagine Canada

April 8, 2021

Abdul Nakua references "Under Layered Suspicion" in the need to rethink regulatory framework.

Read More

National Newswatch

April 7, 2021

Opinion piece by Imam Rashid Mohammed, Vice President of the Canadian Council of Imams.

Read More


April 5, 2021

OMNI-News covers the report, for Canada's diverse citizens.


Reading Muslims

March 30, 2021

Presentation on the report and collaboration between community and academia.



March 29, 2021

CityNews segment covering findings from "Under Layered Suspicion".


Toronto Star

March 29, 2021

Column in Toronto Star featuring Professor Emon and Dr. Hasan.

Read More

NCCM + IIS Press Conference

March 29, 2021

Virtual press conference for launch of "Under Layered Suspicion".



Under Layered Suspicion is a research collaboration between the two authors, whose institutional homes collaboratively incubated their endeavor:

Institute of Islamic Studies

The Institute of Islamic Studies (IIS) at the University of Toronto hosts faculty members and community partners committed to developing new knowledge about Islam and Muslims in Canada. The collaborations aim to make Muslims and their contributions to Canada legible in our national institutions. The IIS’s work comes at a time when Muslims and Islam have been global subjects of legislative agendas, immigration bans, counter-radicalization programs, and vexatious cultural politics.

National Council of Canadian Muslims

The National Council of Canadian Muslims (NCCM) is a national advocacy organization committed to protecting and advancing the civil liberties of Muslims in Canada. NCCM has long received complaints from Muslim-led faith-based charities about aggressive CRA auditing practices against charities serving Canada’s Muslim communities. This report leverages the academic excellence to which the IIS is committed with the public engagement that informs NCCM’s public advocacy.

Logo for the National Council of Canadian Muslims


Anver M. Emon

Professor of Law and History, University of Toronto;
Canada Research Chair in Islamic Law and History;
Director, Institute of Islamic Studies

Nadia Z. Hasan

Chief Operating Officer, National Council of Canadian Muslims


Under Layered Suspicion is supported in part by funding from the Social Sciences and Humanities Research Council.

Logo of the Social Sciences and Humanities Research Council of Canada

Additional funding for this project came from the University of Toronto’s Connaught Secretariat, in its award of a Global Challenge Grant for the Reading Muslims project.

Connaught Fund Logo