19 April 1989 Income Tax Severed Letter 7-3737 - [Feedlot Operators]

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the CRA.
Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle de l'ARC.

MEMORANDUM

DATE APR 19 1989

TO: R. Shultis Director Publications Division

FROM: Small Business and
          General Division
        W.P. Guglich
        957-2102

SUBJECT: Proposed Changes to Interpretation Bulletin IT-156

            Feedlot Operators

The proposed draft of IT-156R was referred to us to respond to a query raised by the XXXX. We have satisfied their concerns. However in dealing with the inquiry we had the opportunity to review the latest draft of the bulletin and in the process note that the reference to other animals has not been deleted as recommended in our memo of December 8, 1988.

We are still of the view that the reference to other animals should be deleted for the reasons given in our earlier memo.

We also note that there is no problem, from our point of view, in deciding whether a taxpayer is a farmer where the animals are raised from birth to market. This also applies to animals raised entirely in coops or pens or to taxpayers carrying on an operation of raising fish in ponds or tanks. Normally all are considered to be farming and any reference to these situations in the feedlot IT is in our view unnecessary.

Finally, we are reluctant to see any comment in the IT referring to other animals when we have no experience or specific legislation to rely on in making our comments. We are concerned with what such comments may mean to tax planners.

for Director General Specialty Rulings Directorate Legislative and Intergovernmental Affairs Branch