CRA indicates that a s. 45 change of use does not restart the 365-day period under the flipped property rules

CRA noted that a deemed disposition and reacquisition under the change-of-use rules in s. 45 apply only for purposes of the capital gains rules in subdivision c of Division B, and not for purposes of the flipped property rules in s. 12, so that the flipped property rules would not be engaged by virtue only of a housing unit having had such a change of use within 365 days of its sale.

Neal Armstrong. Summary of 10 October 2024 APFF Financial Strategies & Instruments Roundtable, Q.4 under s. 12(13).