8 July 1992 External T.I. 5-920633

Where a corporation has acquired vacant land as capital property and not for an income-producing purpose and changes the use of the land by subdividing it into lots and adding services, the exact time of the change in use will be determined in accordance with IT-218R, paragraph 12.

A taxpayer will be allowed to elect under s. 45(2) in relation to a capital property even where it is not a depreciable property subject to the rules contained in s. 13(7)(b).