18 February 2008 External T.I. 2006-0205321E5 F - BAA-corpropriété indivise, QFP-undivided interest -- summary under Qualified Farm or Fishing Property

Two brothers (B1 and B2) hold several pieces of farmland in equal co-ownership. In finding (contrary to an earlier position) that their respective co-ownership interests could constitute qualified farm property, CRA stated:

[T]he term "property" is defined very broadly in subsection 248(1) and … includes an undivided interest of a co-owner in an immovable. … Consequently … an undivided interest in an immovable is, for the purposes of the Act, included in the expression real or immovable property in subsection 110.6(1). In order for the property, which in our view could include an undivided interest of a co-owner of real property, to qualify as qualified farm property, it follows that it must then be determined whether it is reasonable, on the facts, to say that the undivided co-owner used his or her undivided share principally in the course of carrying on the business of farming.

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