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Relief Lending Group (“RLG”) Tax Shelter Program

Why the COIP Promoters Created RLG

In 2008, the same managing minds behind the scenes of COIP tax shelter program, decided to concurrently launch a parallel tax shelter program, from the COIP offices at 27 Kodiak Crescent in Toronto, Ontario. Their original reasons for adding RLG while still promoting COIP were as follows:

[1] to escape the devastating impact of the Toronto Star Special Investigation;

[2] to circumvent the Exclusive Master Agent of the COIP Program (Mr. Darren Weeks and his F.A.S.T. (Fight AIDS Save Tax) network of Ambassadors, headquartered in Alberta and dominant in Western Canada), by concurrently headhunting an additional Master Agent, especially strong in Eastern Canada, who would agree bring their own sales network of agents from a major competing tax shelter at the time, if they had their “own deal”.

[3] to strengthen noticeable areas of unnecessary risk in the COIP program; and

[4] to set up a strategy of staggered promotions, whereby as soon as a prior offering would get audited and/or reassessed by the CRA, that there would be another tax shelter program to promote that had not yet been audited or reassessed.

 

RLG vs COIP

RLG introduced features that were completely new in the Canadian donation tax shelter industry. Efficiencies were introduced that allowed for higher cash-on-cash advantages for participating donors, and which allowed for higher sales commissions for independent sales agents as well.

For example, RLG eliminated the entire “refinancing” arrangement, which was at the heart of the COIP Program, and which required two vendors, two loans, and two charities. Furthermore, in COIP, the vendors were also lenders providing purchase order financing, while in RLG, the vendors and the lenders were always separated. Finally, RLG used a form of “scrip” (a.k.a. the “Credit Certificate” or “Coupon”) as the subject of the loan, rather than the pharmaceuticals being the subject of the loan. This, together with the introduction of the so-called “Right of Reversion”, would allow borrowing participants the option to either pay back cash for the face value of the Coupon (an amount equal to the full contract price of the pharmaceuticals), or to return “identical pharmaceuticals” to the vendor, Agkuran Distributing Ltd. (“Agkuran”) according to specific rules in the contract, in exchange for the reversion of the Coupon, so long as their initial prepaid interest (PPI) would not run out. With the Coupon back in the borrowers’ hands, it could be returned to RLG in complete satisfaction of the debt, and any unaccrued PPI would also be returned to the borrower.

Settling with RLG: by returning identical pharmaceuticals

It follows that such an option (i.e. to exercise the Right of Reversion by opting to return identical pharmaceuticals) would only be attractive to the extent that the price to purchase and return identical pharmaceuticals is less than the original price of the pharmaceuticals that Agkuran sold. Until the advent of the Justice Pharma Debt Settlement Program (the “Justice Program”), no donor/borrower ever succeeded in sourcing any pharmaceuticals whatsoever, and no one settled any debt. This is for two reasons: [1] RLG donors and sales agents were of the same understanding that RLG, several years hence, would help all donors, collectively, by sourcing for them and on their behalf, an independent vendor from around the world, who may be significantly cheaper than Agkuran’s original pharma price, using their unaccrued PPI on account to purchase same; and [2] because it is virtually impossible for any one individual to complete such a technical process.

 

Integrated Receivable Management Inc. (“IRMI”) and Integrated RM

RLG has initiated, escalated, and continues to enforce, serious collection action against all donors/borrowers of the RLG Program using confusing and unlawful tactics. Companies like IRMI and Integrated RM will be able to use signed contracts to obtain judicial decisions that will financially destroy thousands of donors unless they settle through the Justice Program.

It is important to note that IRMI is offering RLG borrowers/donors an “opportunity” to settle debt directly through them. Having a third party collect debt for RLG and others, would normally be allowed; however, it is important to note that the company is considered “non-arm’s length” from RLG for and the other tax shelter promoter companies for a variety of reasons, and therefore any settlement they offer you for less than the face value of the debt may seem attractive, but it is really an unviable solution. First, settling a debt for a donation, with a non-arm’s length third party, for less than the face value of the debt, has the effect of rendering the loan to be “limited recourse”, which has tax consequences of reducing the donation receipt by the loan amount. Second, settling the loan for a cash amount that is less than the face value of the Coupon may stop RLG from pursuing further collection activity with you, but it does nothing to prevent the legal holder of the Coupon, Agkuran, from pursuing you for the face value of the Coupon.

Please note that all Justice Program participants are entitled to receive legal support in connection with ongoing collection demands and threats in relation to the contracts they are settling through the Justice Program.