2 February 1999 External T.I. 9901935 - ANIMAL FOOD

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.

Please note that the following document, although believed to be correct at the time of issue, may not represent the current position of the Department.

Prenez note que ce document, bien qu'exact au moment émis, peut ne pas représenter la position actuelle du ministère.

Principal Issues:

Is the cost of purchasing animal food for cats used to control mice in a barn and guard dogs used to protect farm property deductible in computing the income from the farming business?

Position: Yes.

Reasons:

The expenses are normal expenses with respect to a farming business and are not precluded from deduction by any particular provision of the Income Tax Act.

XXXXXXXXXX 							990193

February 2, 1999

Dear XXXXXXXXXX:

Re: Animal Food

This is in reply to your letter of January 20, 1999 requesting our opinion on whether animal food may be deducted in computing the income of a farming business.

You are particularly interested in the cost of food for “barn cats” used to control mice in barns. You are also concerned with the cost of food for guard dogs used to protect farm property and other farm animals.

Generally, an expense may be deducted in computing the income from a taxpayer’s business, such as a farming business, to the extent the expense was made or incurred by the taxpayer for the purpose of gaining or producing income from the business. The cost of food for animals used for pest control in farm buildings and the safeguard of farm property and other farm assets would usually fall within the above requirement.

We hope our comments are helpful but since they do not constitute an advance income tax ruling, are not binding on the Department with respect to any particular business.

Yours truly,

for Director
Business and Publications Division
Income Tax Rulings and
Interpretations Directorate
Policy and Legislation Branch