Immediately prior to the amalgamation of Holdco with Opco, the only assets of Opco were woodlots. In finding that the cost of the land could not be bumped under ss. 87(11)(b) and 88(1)(d), CRA noted:
… IT-481 ... [states], " If a taxpayer acquires land on which there is standing timber (for example, freehold timberlands), such property is a timber limit.” and “Unlike land on which is located a property which qualifies for inclusion in one of the classes in Schedule II of the Regulations, land which is acquired as a part of a timber limit is depreciable under Schedule VI of the Regulations and does not exist as a separate property for purposes of the Act.”