January 2, 1990
| Mr. L. Farber | R.D. Weil |
| Director | (957-2066) |
| Tax Policy and Legislation Branch | F-3288 |
| Department of Finance | |
| 140 O'Connor Street | BY HAND |
| L'Esplanade Laurier | |
| 17th Floor, East Tower | |
| Ottawa, Ontario, K1A 0H5 |
Dear Len:
Deferred Cash Purchase Tickets Subsections 76(4) and (5) of the Act
In August, 1988, the Canada Grain Act was amended to allow "cash purchase tickets" to be issued by a "grain dealer" as well as a primary elevator or a process elevator. Based on the wording of subsection 76(4) of the Income Tax Act, such tickets do not qualify for deferred status.
As well, in the same month, the Canadian Wheat Board Act was amended to expand the definition of "grain" to include "canola". Based on the wording of subsection 76(5) of the Income Tax Act, canola does not qualify as grain for purposes of subsection 76(4).
We would appreciate receiving your views as to whether these results are consistent with intended tax policy. Excerpts from the revised statutes are attached for your convenience. If you have any questions concerning this matte, please contact Rob Weil at the above number.
Yours sincerely,
B.J. BrysonActing DirectorCurrent Amendments and Regulations Division
RDW/Attachments
c.c. Mr. G. Keable