Principal Issues: The taxpayer requests our opinion on whether a personal trust may designate two properties, for the purposes of the principal residence exemption, for the same taxation year.
Position: For a particular taxation year, a personal trust may designate one of its properties for the purposes of the principal residence designation.
Reasons: The mechanics of paragraphs 40(2)(b) and 54(c) of the Act only allow the personal trust, as the taxpayer, to designate one particular property as its principal residence.