Ms. Brown purchased a home in London, Ontario in 2008 at a cost of $260,000. She lived in the home until January 29, 2013, at which time she moved to Toronto and rented a home in Toronto. At the time of the move, Ms. Browns London, Ontario residence had risen in value to $430,000. Expecting that real estate prices would continue to rise, Ms. Brown chose to retain ownership of her London, Ontario home and rented it to a third party.

In June 2020, Ms. Brown decided she missed living in London, Ontario and chose to return. She returned to London, Ontario where she took up residence in her London home. At the time, the London, Ontario residence had a fair market value of $630,000. In March 2023, Ms. Brown decided she was tired of living in the city. She sold her London, Ontario home for $984,000 and moved to the countryside. Assume that the real estate fees in 2023 were 5% of the selling price (FMV of the home).

Prior to filing her 2023 personal tax return, Ms. Brown has requested your advice in minimizing the capital gains she must report on the sale of her home.

Required:

Calculate the minimum capital gain for Ms. Brown on the sale of her home under the following

Circumstance (remember to show all your work to get full marks):

(A) Assuming that the Ms. Brown elected to not to make a 45(2) election (which an election to deem her property to not have a changed use) (ie this 45(2) election was never made).