Principal Issues: 1. Whether a partial change in use and deemed disposition pursuant to paragraph 45(1)(c) of the Act is considered to have occurred when a taxpayer undertakes a qualifying renovation to their eligible dwelling to create a secondary unit in accordance with the requirements of the MHRTC.
2. Whether a taxpayer’s secondary unit forms part of their principal residence for purposes of claiming the principal residence exemption pursuant to paragraph 40(2)(b) of the Act on a future disposition of their property. That is, whether the secondary unit (for instance, a basement suite or laneway home) and the primary residence are considered one housing unit of the taxpayer.
Position: Question of fact.
Reasons: 1. Whether a partial change in use and deemed disposition of a taxpayer’s property occurs (pursuant to paragraph 45(1)(c) of the Act) where a taxpayer makes a qualifying renovation to their eligible dwelling (which establishes a secondary unit) according to the requirements of the MHRTC, is question of fact and can only be made on a case-by-case basis, having regard to all the facts and circumstances of the particular taxpayer’s situation. However, since the MHRTC legislation in section 122.92 of the Act, does not impose any requirement on the taxpayer to use the secondary unit for rental or income earning purposes, and the use of the secondary unit is as a dwelling for a taxpayer’s family (that is, a qualifying individual or their qualifying relation), it is possible that in some circumstances the partial change in use rules in paragraph 45(1)(c) will not apply.
2. A taxpayer that constructs a secondary unit that is a self-contained housing unit according to the requirements of the MHRTC would generally be considered to have two separate housing units. Nonetheless, where a taxpayer uses the secondary unit for personal purposes rather than as a rental (that is, as a rental property that is a source of income for the taxpayer), and they are able to demonstrate that the two housing units are sufficiently integrated and are being used together and are functioning as one, then it may be possible to conclude that the entire property is one housing unit and as such, may be eligible for the PRE.