I think it has something to do with not being a lottery, but having to buy something to win. If you buy coffee & have the chance to win, but there is no skill-testing question, it is a lottery & therefore must be licenced as such & is subject to certain taxes. Its basically a loophole so that Tim Hortons or whatever company can have giveaway promotions without having to pay a portion of their added profits as tax.
Another loophole is when you have the no purchase necessary BS. Of course purchase is necessary to win, but if they toss a drawbox in the store selling the product, with those little pads of paper to fill out, it is no longer a purchase required lottery. Of course you know, you're not winning anything unless you buy.
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