In the situation where a taxpayer, who for many years has used his residence for personal use, commences in June 2024 to rent it out (without making a s. 45(2) election) so that the s. 45 rules apply, and then sells it in April 2025, will such sale be subject to s. 12(12)?
CRA noted that a deemed disposition and reacquisition under s. 45 apply only for purposes of the capital gains rules in subdivision c (but not the income provisions of subdivision b) of Division B of Part I, so that there would have been no resulting disposition or reacquisition for purposes of the flipped property rules.