CRA finds that the four-unit requirement for the purpose-built rental housing rebate must be satisfied by one building

One of the requirements for the purpose-built rental housing (PBRH) rebate is that there be a multiple-use residential complex (MURC) containing a minimum of four “qualifying residential units” (as defined in s. 256.2(1)), each with separate kitchens, baths, and private living areas. CRA considered that this requirement would be satisfied if there were two adjoining duplexes (each with two such units) with a shared wall, because there therefore would be one residential complex. On the other hand, if there were two adjoining duplexes on a single plot of land without much physical interconnection between the two structures, each would constitute a separate building rather than forming a single MURC, so that the 4-units-in-one-residential-complex requirement would not be satisfied.

If CRA had wished to reach the opposite conclusion in the second situation, it perhaps could have applied s. 33(2) of the Interpretation Act (references to the singular include the plural) to find that one plot of land with two buildings on it constituted a residential complex.

Neal Armstrong. Summary of 3 September 2024 GST/HST Interpretation 247914 under Real Property (GST/HST) Regulations, s. 4(2)(a) and summary of 14 August 2024 GST/HST Interpretation 247708 under Real Property (GST/HST) Regulations, s. 4(2)(a).