22 March 2006 External T.I. 2005-0131231E5 F - Perte et avantage au titre du logement -- summary under Subsection 6(21)

At what point in time must the housing loss in respect of a residence be calculated?

CRA indicated that the intention in using the phrase "at any time" was “to allow for flexibility and to accommodate the different scenarios envisaged when relocating employees," and went on to state:

[S]ince the calculation of the housing loss affects the application of subsection 6(20) relief, it would be preferable to calculate the housing loss at a point in time that does not disadvantage the taxpayer in a particular situation. For example, you may be able to benefit from the housing loss at the time of taxation of the amount paid and received as a housing loss on account of an office or employment and not only on the actual sale of the residence.

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