Homebrew laws governing me, OP.
http://www.agco.on.ca/en/faqs/faqs_alcohol.aspx
I don't think they will come after me if I get empty bottles to contain the beer I am giving away.
Comments about Canada being outside of the TTB's control are correct however the laws aren't exactly more forgiving up in Canada.
This links to the FAQ of the AGBO (Alcohol and Gaming Board of Ontario) not exactly legal authority on the technical nature of the law, this page is designed for the very common questions the board gets with general answers.
The only relevant question is # 6
"Can I make alcohol at home?"
the answer from the website is:
"You may make beer or wine at home as long as it is only for your personal consumption or to be given away free of charge. Homemade (or "u-brew")
beer or wine may not be sold or used commercially.
The AGBO is created and required to abide by the Ontario Liquor License Act. R.S.O 1990 you can find a copy of it here:
http://www.e-laws.gov.on.ca/html/statutes/english/elaws_statutes_90l19_e.htm#BK4
s. 5(1) of the Act clearly sets out 5. "No person shall keep for sale, offer for sale or sell liquor except under the authority of a licence or permit to sell liquor or under the authority of a manufacturers licence."
this makes it plainly clear that you may not sell liquor in Ontario without a license. Now I know you argument is you're not selling you're bartering, renting, trading, exchanging etc. however you're still screwed because s. 1(1) of the act defines
selling to include:
"sell means to supply for remuneration, directly or indirectly, in any manner by which the cost is recovered from the person supplied, alone or in combination with others, and sale has a corresponding meaning;
so to sum up you may not without a license in Ontario: sell, supply for renumeration (money or goods of any kind) directly or indirectly, in any manner by which the cost is recovered from the person supplied, alone or in combination with others alchohol.
Also keep in mind that Canadian courts often take a much more purposive approach to interpretation then our American counter parts. Feel free to find a loop-hole and then argue your exchanging, renting or whatever is not caught by the purpose of the Act.
The bottom line is that selling your beer is illegal, further, exchanging your beer for anything of value, including additional bottles, is also illegal.
In reality you'll probably get away with it, even if you turned yourself in to the police station they likely wouldn't spend the resources to prosecute you, and most people probably won't see this as some grave injustice you've gotten away with, but don't try and come up with some sly argument that shows its legal and certainly don't post on the freaking internet about what you're doing.
Oh In case you were wondering s. 61(1) of the Act quoted above makes it an offence to violate any provision of the act.
The penalty for violation is set out in s.61(3)b for individuals it is a fine not more than $100,000 or one year imprisonment or both.