The challenge is that the current legislation has provisions of deemed sales when a rental building has to be self-supplied, and that occurs, by the court's definition, in the primary market where that property is taxable. Because of the lack of transactions in the primary market, CRA appraisals and outside appraisals have to reach to the secondary market and utilize exempt used residential sales in their application and estimate of value for new rental projects. There are adjustments that come in that have to be applied between a primary and a secondary market, and those adjustments create a lot of issues with the industry.
Also, the CRA appears to be lacking any knowledge that the risk associated with deemed supply when a rental building is new and not occupied is much higher than it is with fully occupied, used residential with no tax liability attached to it. There's a difference in looking at the market transactions from one market and applying them to the deemed legislation, which explains that the self-supply has to occur when the first occupancy is triggered.