21 February 2012 External T.I. 2011-0417471E5 F - Changement d'usage - paragraphe 45(3) -- summary under Property

A taxpayer inhabited as a principal residence a unit of a taxpayer-owned duplex and integrates that unit, through major renovations, with the other unit in the duplex that was, before those renovations, rented to third parties.

CRA indicated that “An immovable is normally considered to be a single property unless it is legally subdivided into two or more separate properties,” so that, in this situation, the partial change-in-use rule in s. 45(1)(c) would be considered to apply.

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