24 June 2024 External T.I. 2023-1000061E5 - Meaning of "wood waste" -- summary under Wood Waste

Does “wood waste” include waste generated from (i) forestry operations, including slash piles, (ii) provincially/territorially regulated forest management activities that support improving the health of forest stands and forest fire resiliency (e.g., residues from stand thinning, salvaged wood from fire/pest affected stands, residues from fire smarting), and (iii) construction and demolition activities.

CRA first stated:

[T]here is no inherent limitation to the activity or process from which the waste is generated.

After going on to refer to Dictionary definitions of “wood” and “waste,” it concluded:

[I]t appears as though “wood waste” would generally mean an unwanted material or by-product that would otherwise be discarded and that consists of the substance that is found in parts of trees, shrubs, etc. …

[M]aterial salvaged from each of the activities outlined above could be captured by the definition of “wood waste” … provided that it is waste and that it has maintained its physical and chemical properties of wood.

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