A taxpayer purchased the right to cut, over a period of 10 years, Christmas trees on another taxpayer's land for a lump sum payable over 4 years. In finding that this cutting right was not a property referred to in Reg. 1100(1)(e) (and before finding that it was a Class 14 property), CRA reiterated its position in IT-373R2, para. 15 that:
A stand of Christmas trees is not viewed as a timber limit since the output is trees, not timber or similar products, and the capital cost allowance in Schedule VI of the Income Tax Regulations is not applicable.