6 October 2008 External T.I. 2008-0271421E5 F - Terres à bois-plan d'aménagement forestier Québec -- summary under Farming

Before describing the requirements for a rollover under s. 73(3) (or 70(9), CRA noted the distinction in IT-373R2, para. 14 (approved in Desrosiers Estate) between a woodlot operation that was a farm (entailing “planting, nurturing and harvesting trees pursuant to a forestry management … plan and significant attention … paid to manage the growth, health, quality and composition of the stands”) and a logging operation, and that if the correspondent’s statement that “the land was used principally in a logging business” was correct, then the rollover would not be available.