6 October 2008 External T.I. 2008-0271421E5 F - Terres à bois-plan d'aménagement forestier Québec -- summary under Paragraph 70(9)(a)

Work was carried out on some of the woodlots of a taxpayer, with a forest producer's certificate under s. 120 of the Québec Forest Act and also forest management plans issued by the Minister of Natural Resources and Wildlife, in accordance with those plans, was not performed on a timely basis for other lots - and some woodlots did not require any work under the plan. Regarding the last point, CRA stated that the “engaged” test “may be satisfied with respect to a woodlot even if no work has been done, as long as the forest management plan does not require any work or task to be performed.”