11 June 1990 Income Tax Severed Letter ACC9528 - Non-profit Status of Organization

June 11, 1990

OTTAWA DISTRICT OFFICE                         
Enquiries and Office                           C. Tremblay
  Examinations                                 957-2095
2nd Floor, 360 Lisgar Street 

Ed Kutckewich
                                                900256

                                                EACC 9528

Dear Sirs:

This is in reply to your memorandum of March 29, 1990, concerning
the non-profit status of                     24(1)           and
whether the               24(1)              is organized
according to the provisions of paragraph 149(1)(1) of the Income
Tax Act (the "Act").

From a review of the Constitution and By-laws, it would appear
that the      24(1)      is exempt from Part 1 Tax under
paragraph 149(1)(e) of the Act, that an agricultural organization
is an entity organized and operated for one or more of the
following purposes: the advancement or furtherance of
agricultural; the betterment of the conditions of those engaged
in such pursuits; the improvement of the grade or quality of
their pursuits or the development of a higher degree of
efficiency in their respective occupations. 

24(1)              would, in our view, be considered to be an
agricultural organization.  Thus, if this is the case, you need
not be concerned about the accumulation of interest as paragraph
149(1)(e) of the Act contains no words similar to those in
paragraph 149(1)(1) of the Act that state "...for any other
purpose except profit".

We trust our comments are of assistance

for Director Business and General Division Legislative and Intergovernmental Affairs Branch