In the course of a discussion indicating that it considers there to be a single property for s. 248(21) purposes if separtate lots (e.g., two lots separated by Crown ownership of a stream or by another taxpayer's property) had been acquired under a single deed, CRA stated:
Paragraph 248(21)(c) of the Act allows for a parcel of land being assembled or consolidated and then subdivided in contemplation of a partition.