CRA indicates that a nursing home is not, and a typical rooming house is, a “housing unit” for flipped property purposes

Regarding whether a nursing home or a rooming house was a flipped property, CRA first indicated that it considered that a “housing unit is normally represented by a room, or a group of rooms, used for residential purposes, occupied by a person or group of persons, and which includes a certain number of characteristics such as a kitchen, bathroom, etc.”, and that the term “housing unit” was restricted to single housing unit.

CRA then stated:

Although a nursing home may contain elements of a housing unit (such as a kitchen, bathrooms, etc.), it is our view that a nursing home would generally not be considered a flipped property.

It is unclear whether this is reflecting a view that a nursing home is a care rather than residential facility (see Blanche’s Home Care).

Turning to a rooming house, where individual rooms are rented out but the residents share a kitchen and bathroom facilities, it stated:

[W]e would generally consider the rooming house to be a property that is one housing unit for purposes of the flipped property rules – i.e., it is a room or group of rooms used for residential purposes, occupied by a person or group of persons, with a certain number of elements such as a kitchen, bathroom, etc.

Even if each bedroom went beyond basic furnishings to include a mini fridge, table and basic cooking setup such as a small stove or hot plate, CRA considered that such room would not constitute a housing unit, so that the property would not be excluded from “housing unit” status through having multiple housing units.

Neal Armstrong. Summary of 18 December 2025 External T.I. 2025-1055741E5 under s. 12(13)(a).