Erickson v. The Queen, docket 1999-5065-GST-I (Informal Procedure) -- summary under Substantial Renovation

By services, 14 March, 2025

The owner renovated his home such that its square footage was doubled, and a garage and second floor were added. He conceded that he had not substantially renovated the existing premises. In confirming the Minister’s denial of the GST new housing rebate referred to in s. 256(2) (which was made on the basis that owner did not construct a residential complex as defined in s. 123(1)), Hershfield J. found (at para. 15) that the renovations did not qualify as the construction of a new home given that the existing premise were not “essentially reduced to a relatively minor aspect of that new premises.” He went on to state (at paras. 16):

Adding a double garage and doubling your living space in a home does not constitute anything more than a significant renovation. The Act does not permit a rebate on a renovation, significant or otherwise, unless virtually all of the existing premises is gutted.

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a renovation does not qualify as substantial unless virtually all of the existing premises are gutted
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