7-910048
Subject: Forestry Issue Report # 02 CCA on assets used on perpetual yield timber limits
We are writing in reply to your memorandum of December 20, 1990 requesting our confirmation that the positions relied upon by you which are reflected in report # 02 are the current policies of Rulings in regards to the issue of whether immovable assets are disqualified from inclusion in either Classes 10(n) and 15 in situation where such assets are related to timber limits managed on a perpetual yield basis.
We confirm that our general position with respect to CCA on assets used on perpetual yield timber limits as stated in our memorandum dated October 31, 1988 (7-3096) continue to be our current position on the matter.
However, we would suggest that you consider defining such expressions as "managed on a perpetual yield basis" and "immovable assets" in report # 02 under a new heading "Background" in order that the uninformed reader may fully understand the matter.
We hope that our comments are helpful to you.
DirectorBilingual Services & ResourceIndustries Division Rulings Directorate