2 September 1992 Memorandum (Tax Window, No. 24, p. 17, ¶2222)

The sale of cutting rights for a fixed price for a fixed quantity of timber to be taken within a fixed period of time will not be subject to s. 12(1)(g).

Proceeds received by land owners from the sale of logs and wood products are included in their income. However, where the removal of trees is occasional and incidental to their principal business activity, proceeds from the sale of cutting rights will be capital receipts which reduce the adjusted cost base of the land.