Words and Phrases - "constructs ... a residential complex"

The owner renovated his home such that its square footage was doubled, and a garage and second floor were added. He conceded that he had not substantially renovated the existing premises. In confirming the Minister’s denial of the GST new housing rebate referred to in s. 256(2) (which was made on the basis that owner did not construct a residential complex as defined in s. 123(1)), Hershfield J. stated (at para. 15):

[A]n addition will not give rise to rebates unless it incorporates (consumes) a pre-existing premises to the point where the addition is essentially the new residential premises and the pre-existing premises, having ceased to exist as a residential unit is essentially reduced to a relatively minor aspect of that new premises. If renovations which are expressly provided for under the Act must be so substantial as to require virtually gutting all of a pre-existing premises to qualify for a rebate, additions, for which there are no express provisions in the Act, should (if they are to be considered at all) presumably be more substantial yet. An addition that doubles square footage by adding a few rooms in any direction will not qualify for a rebate applying these criterion, even if the character of the residence has been modified in the process.