Section 207.31 - Tax payable by recipient of an ecological gift

A municipality received multiple parcels of land as an ecological gift and now is considering changing the use of some but not all parcels of land without the authorization of the Minister of the Environment. What are the implications under s. 207.31? CRA responded:

If… the recipient received a gift of one property, then the tax under section 207.31…would be applied based on the fair market value of all the parcels at the time of change in use. If, however, … there was a gift of multiple separate and distinct properties… the tax [would apply] on a property-by-property basis… .

[I]t is possible to interpret the words of section 207.31… such that the tax could be applied more than once on the same property where the property undergoes multiple changes in use over time… .