The taxpayer, an integrated forest products company, realized net capital gains from the disposition of two BC saw mills and a capital loss from the disposition of Ontario housing assets that had been used for managers of an Ontario pulp and paper mill. After being assessed in British Columbia for BC logging tax on the basis that the net capital gains were "income derived from logging operations," and therefore subject to the logging tax under BC's Logging Tax Act, the taxpayer amended its federal income tax return in order to claim logging tax credits under s.