CRA finds that an Alberta coniferous tree-harvesting right was a timber resource property
Rather than reviewing the quite complex jurisprudence on what is a timber resource property, CRA looked at a timber removal right that was effectively a renewal of some timber removal rights that had been granted by the Alberta government in 1967 and 2004, and simply stated:
Based on jurisprudence … and the facts and assumptions described above, the New Quota (whether it is viewed as a single property or a combination of two properties) would qualify as a timber resource property pursuant to the definition of that term in subsection 13(21).
As such, its sale would give rise to full income-account treatment rather than the potentially more favourable treatment accorded to timber limits or eligible capital property (or Class 14.1 properties).
Neal Armstrong. Summary of 6 February 2018 External T.I. 2017-0732151E5 under s. 13(21) – timber resource property.