Three equal co-owners of a single parcel subdivide a portion of that original parcel into 150 lots and then partition so that each is the sole owner of 50 lots (while continuing to hold the remaining portion of the original parcel as co-owners – then subsequently, subdivide that remaining parcel into 120 lots and partition so that each becomes the sole owner of 40 lots.
CRA agree with the submission that s. 248(21) also applied to the second partition on the basis that the remaining parcel was a single property to which s/ 248(21) could apply.