Tribunals Ontario
Tribunaux décisionnels Ontario
Assessment Review Board
Commission de révision de l’évaluation foncière
ISSUE DATE: January 05, 2024
FILE NO.: WR 184494
Assessed Person(s): Medallion Developments (Bayly Square) A Limited; Medallion Developments (Bayly Square) B Limited
Appellant(s): Medallion Developments (Bayly Square) A Limited; Medallion Developments (Bayly Square) B Limited
Respondent(s): Municipal Property Assessment Corporation Region 13
Respondent(s): Town of Ajax
Property Location(s): 61-73 Bayly Street West; 420 Hardwood Avenue South
Municipality(ies): Town of Ajax
Roll Number(s): 1805-040-006-24790-0000; 1805-040-006-24781-0000
Appeal Number(s): See Schedule A
Taxation Year(s): 2018, 2019, 2020, 2021, 2022 and 2023
Hearing Event No.: 780470
Legislative Authority: Sections 33, 34 and 40 of the Assessment Act, R.S.O. 1990, c. A.31
APPEARANCES:
Parties Medallion Developments (Bayly Square) A Limited; Medallion Developments (Bayly Square) B Limited Counsel Ian Andres; Rodney Gill
Parties Municipal Property Assessment Corporation Counsel Karey Lunau
Parties Town of Ajax Counsel Richard Minster; Dan Rosman
HEARD: June 29, 2023 by video conference
ADJUDICATOR(S): Christopher Voutsinas, Vice-Chair
DECISION
OVERVIEW
1Medallion Developments (Bayly Square) A Limited, and Medallion Developments (Bayly Square) B Limited (“Appellant(s)”) are the owners of 61-73 Bayly Street West, roll number ending in 24790 and 420 Harwood Avenue South, roll number ending in 24781 (the “Subject Property(ies)”), respectively. The Subject Properties are located in the Town of Ajax (“Municipality”) and form part of a masterplan multifamily residential development.
2A number of appeals related to the Subject Properties have been filed pursuant to sections 33, 34, and 40 of the Assessment Act, R.S.O. 1990, c. A.31 (“Act”) for the 2018-2023 taxation years. The Appellants take the position that: (I) the assessed values of the Subject Properties are incorrect and too high and; (II) the property classification of the Subject Properties as Multi-Residential (MT) is incorrect and that the correct property classification of the Subject Properties is New Multi-Residential (NT). See Schedule A for a list of the subject appeals.
3For clarity, the outstanding appeals for 61-73 Bayly Street West relate to the 2018-2023 taxation years, and for 420 Harwood Avenue South relate only to the 2020- 2023 taxation years.
4The Municipal Property Assessment Corporation (“MPAC”) and the Municipality oppose the appeals and take the position that the Multi-Residential (MT) property classification for the Subject Properties is correct. The correct property class of the Subject Properties is the remaining issue in dispute in these appeals. As explained below, the issue of the correct current values has been resolved by agreement of the parties.
Description of the Properties
5The Subject Properties comprise two midrise multifamily residential apartment towers and associated commercial/retail uses that together form phase 1 of a multi-phase masterplan development situated in the Town of Ajax.
Areas of Agreement
6The parties have reached a settlement agreement, “Agreement on Property Values” dated January 23, 2023, regarding the correct current values of the Subject Properties. The agreed values are dependent upon and vary based on the Assessment Review Board’s (“Board”) determination of the correct property classification of the Subject Properties as either Multi-Residential (MT) or New Multi-Residential (NT).
7As a result of the foregoing, the correct current values are no longer in dispute in these appeals.
Issue for the Hearing
8Remaining at issue in this proceeding is:
- What is the correct property classification of the Subject Properties pursuant to the Act?
Result
9The Board finds that, for the taxation years in question, the correct property classification of the Subject Properties is the New Multi-Residential property classification (NT).
Background
10The lands upon which the Subject Properties are constructed were acquired from the Corporation of the Town of Ajax pursuant to a Development Agreement and Agreement of Purchase and Sale dated July 22, 2011, as amended February 3, 2016 (“Agreements”). The masterplan development comprises of three phases on a total of nine acres of land zoned to permit the construction of over 1,800 residential apartment units, with underground parking, in six buildings of up to 25 storeys each, along with 72,000 square feet of combined retail and commercial space. The first phase consists of the Subject Properties and comprises of two buildings facing onto a public square, Pat Bayly Square, at the corner of Bayly Street and Harwood Avenue in the Town of Ajax.
11The Subject Property located at 61-73 Bayly Street West (known as Building A of the masterplan development) is a rental apartment building comprised of 274 residential units. Occupancy of the residential units occurred in stages commencing April 2018. The building was added to the assessment roll in 2018.
12The Subject Property located at 420 Harwood Avenue South (known as Building B) is a rental apartment building comprised of 307 residential units. Occupancy of the residential units occurred in stages commencing February 2020. The building was added to the assessment roll in 2020.
13The Appellants take the position that the classification of the Subject Property located at 61-73 Bayly Street West (Building A) is incorrect for the 2018-2023 taxation years, as the residential component of the development was assessed in the Multi-Residential (MT) property class but should be assessed in the New Multi-Residential (NT) property class. Similarly, the Appellants take the position that the classification of the Subject Property located at 420 Harwood Avenue South (Building B) is incorrect for the 2020 to 2023 taxation years, as the residential component of the development was assessed in the Multi-Residential (MT) property class but should be assessed in the New Multi-Residential (NT) property class.
ANALYSIS AND FINDINGS
Issue 1 - What is the correct property classification of the Subject Properties pursuant to the [Act](https://www.canlii.org/en/on/laws/stat/rso-1990-c-a31/latest/rso-1990-c-a31.html)?
The Regulation
14Section 10(2) of O. Reg. 282/98 (“Regulation”) states:
(2) The new multi-residential property class consists of land described in paragraph 1 of subsection 4 (1) whose units have been built, or converted from a non-residential use, pursuant to a building permit issued,
(a) on or after April 20, 2017; or
(b) before April 20, 2017, if, at the time at which the permit was issued, a by-law was in force that opted to have the property class apply in the municipality, in accordance with subsection (1) of this section as it read immediately before it was revoked by O. Reg. 264/17. O. Reg. 264/17, s. 1 (2).
15The reference to paragraph 1 of subsection 4(1) – the multi-residential property class definition – requires that the land include a building with seven or more self-contained residential units. This is the case here and not in dispute.
Appellants’ Position
16The Appellants take the position that the New Multi-Residential (NT) property class applies to the Subject Properties for the respective taxation years in question because there are more than seven self-contained residential units in each of the new buildings, all of which were built pursuant to a building permit issued by the Municipality after April 20, 2017.
17The Appellants submit that partial permits were issued after April 20, 2017, that partial permits are permits, and that the residential units could not have been completed without, and until after, the full building permits were issued - October 13, 2017 in the case of Building A, and May 31, 2019 in the case of Building B - both of which are issued “after April 20, 2017”.
18At the hearing, the Appellants took the position that the residential units could not be completed with any of the of the permits issued other than and only pursuant to the “Full” building permit which allowed for the completion of the buildings and the residential units, and that they could not have completed the units without this permit. The Full permit in the case of both Subject Properties was issued after April 20, 2017.
19The Appellants referred to “The Corporation of the Town of Ajax By-law Number 45-2014 (Repealed by 37-2018) and By-law Number 37-2018 (Repealed by 31-2019), each in evidence, that state “partial permit means a permit issued by the chief building official to construct part of a building” and “permit means permission or authorization given in writing by the chief building official to perform work, to change the use of a building or part thereof, or to occupy a building or part thereof…”
20At the hearing, the Municipality’s witness, Steven McReelis, Chief Building Official and Manager of Building Approvals, Town of Ajax, confirmed on cross-examination that: a) partial building permits allow construction to commence in advance of approval of the Full permit; b) construction cannot proceed beyond the stage approved by the partial permit; c) the builder cannot start to enclose the building and complete construction without the Full permit; c) that there is no guarantee of further permits being issued; and d) the Building By-laws refer to partial permits as permits.
21In addition, the Appellants assert that while several partial permits were issued after the initial partial permit (i.e., permit 13 101971 RM in the case of Building A, and permit 16 106883 in the case of Building B), that the document as displayed at that subsequent issued date did not exist at the time of the initial issued date. For example, while the building permit for Building A (partial permit 13 101971 RM) is dated July 15, 2013, the Full building permit is shown under the Special Conditions section of partial permit 13 101971 RM with an issued date of October 13, 2017 (notwithstanding partial permit 13 101971 RM continues to reflect the initial issued date of July 15, 2013). See the tables in paragraph 37 and 38 for further information.
22The Appellants take the position that the language used in the Regulation is clear and unambiguous on plain reading, and that the correct property classification is New Multi-Residential (NT).
MPAC and the Municipality’s Position
23MPAC and the Municipality oppose the appeals and take similar positions on the property classification of the Subject Properties, so the Board will address them together. MPAC and the Municipality take the following position:
The New Multi-Residential property class applies to newly built residential apartments that, in Ajax, were built pursuant to a building permit issued “on or after April 20, 2017” and that the building permits for the new units at each of the Subject Properties were issued prior to April 20, 2017. As such, the units do not qualify for the New Multi-Residential property class.
Only buildings whose units have not been built pursuant to permits issued before April 20, 2017, are eligible to be placed in the New Multi-Residential property class.
Building A (Bayly) was built pursuant to two building permits. The first is the “shoring only” permit issued July 4, 2013, number 12-108209. As noted on the shoring permit “a separate permit is required for the construction of the building.” The second building permit was issued July 15, 2013. This is building permit number 13-101971 RM which authorized the construction of the foundation and the entire building (emphasis added). They assert that this building permit authorized the complete construction and was updated in stages via subsequent partial permits (e.g., superstructure, mechanical and plumbing, full building, etc.) and that the permit number never changed.
Building B (Harwood) was also built pursuant to two building permits. The first is a “shoring only” permit issued July 8, 2016, number 16-103214. The second building permit was issued November 10, 2016, number 16-106883 which authorized the construction of the foundation and the entire building (emphasis added). They assert that this building permit authorized the complete construction and was updated in stages via subsequent partial permits (e.g., superstructure, mechanical and plumbing, full building, etc.) and that the permit number never changed.
The Municipality asserts that the Regulation refers to the permit that initially caused the units to be built (emphasis added). The units are part of, and the primary reason for, these developments. Further, they assert that there was no other contemplated purpose for the initial building permits other than to construct rental apartment buildings and that the units were under construction prior to the April 20, 2017 date.
MPAC stated at the hearing that the original building permit is the effective permit (emphasis added) and the date of that permit represents the effective date for purposes of classification. At the hearing, MPAC noted that only partial permits were issued after the April 20, 2017 date (emphasis added).
In addition, the Municipality asserts that because properties in the New Multi-Residential property class are taxed at a lower rate than those in the Multi-Residential property class the purpose of the Regulation is “to incentivize developers to initiate projects after April 20, 2017”. The Municipality asserts that the Board must look to the purpose of the Regulation to answer the question at hand.
24At the hearing, MPAC stated that while the purpose of the Regulation was to encourage development - the Subject Properties were already under development.
25Further, in its written closing submissions, the Municipality cites Vandenheede Farms Limited v. Norfolk (County) Chief Building Official, 2011 ONSC 1525 at paragraph 22 which states that a partial permit is a class of building permit that allows a portion of the project to be completed while issuance of a building permit for the complete building remains pending. A partial permit issued pursuant to the Building By-law is a building permit within the meaning of subsection 8(1) of the Building Code Act, and as would be the case for a building permit for the complete building, the requirements of subsection 8(2) of the Building Code Act must be complied with in order for the partial permit to issue.
26Also, the Municipality relies on Ayerswood Development Corporation v. London (City), 2006 CanLII 18521 (ON SCDC), at paragraph 35, and City of Toronto v SheppBonn Ltd., 2015 ONSC 3829, at paragraph 4, reflecting the principle that the chief building officer has no discretion to refuse a building permit if all legal requirements for its issue have been met and is otherwise obliged to issue the building permit.
Principles of Statutory Interpretation
27As the only issue raised in this hearing requires a statutory interpretation of section 10(2) of O. Reg. 282/98, it is necessary that the Board apply the relevant principles of statutory interpretation.
The Ordinary Rule of Statutory Interpretation
28When it comes to interpreting the Regulation, the ordinary rule of statutory interpretation is that "the words of an Act are to be read in their entire context and in their grammatical and ordinary sense harmoniously with the scheme of the Act, the object of the Act, and the intention of Parliament" (Bell ExpressVu Limited Partnership v. Rex, 2002 SCC 42, [2002] 2 SCR 559 at paragraph 26).
29In their submissions, the Municipality also cites Magnum Opus Developments (Victoria Park) Corporation v. Municipal Property Assessment Corporation, Region 09, 2022 CanLII 1610 (ON ARB) (“Magnum”), at paragraph 23, where the Board states in its decision: To determine the Properties’ correct property class the Board must determine the intention of the legislator and the context and purpose of the legislation in order to guide its reading of the Regulation. In Canada (Minister of Citizenship and Immigration) v. Vavilov, 2019 SCC 65, [2019] 4 SCR 653, at paragraphs 117-124, the Supreme Court of Canada clarified that a tribunal’s interpretation of legislation must be consistent with its “text, context and purpose.”
Presumptions
30In Québec (Communauté urbaine) v. Corp. Notre-Dame de Bon-Secours, 1994 CanLII 58 (SCC), [1994] 3 SCR. 3, the Supreme Court of Canada states with respect to the interpretation of tax legislation:
The rules … may be summarized as follows:
− The interpretation of tax legislation should follow the ordinary rules of interpretation;
− A legislative provision should be given a strict or liberal interpretation depending on the purpose underlying it, and that purpose must be identified in light of the context of the statute, its objective and the legislative intent: this is the teleological approach;
− The teleological approach will favour the taxpayer or the tax department depending solely on the legislative provision in question, and not on the existence of predetermined presumptions;
− Substance should be given precedence over form to the extent that this is consistent with the wording and objective of the statute;
− Only a reasonable doubt, not resolved by the ordinary rules of interpretation, will be settled by recourse to the residual presumption in favour of the taxpayer.
31In Placer Dome Canada Ltd. v. Ontario (Minister of Finance), 2006 SCC 20, [2006] 1 SCR 715, at paragraph 24, the Supreme Court of Canada also stated:
Although there is a residual presumption in favour of the taxpayer, it is residual only and applies in the exceptional case where application of the ordinary principles of interpretation does not resolve the issue: Notre-Dame de Bon-Secours, at p. 19. Any doubt about the meaning of a taxation statute must be reasonable, and no recourse to the presumption lies unless the usual rules of interpretation have been applied, to no avail, in an attempt to discern the meaning of the provision at issue.
32Further, in the same decision at paragraph 23, the Supreme Court of Canada states that where a provision is precise, clear, and “admits of no ambiguity in its meaning or in its application to the facts, it must simply be applied.” To clarify, “legislative purpose may not be used to supplant clear statutory language, but to arrive at the most plausible interpretation of an ambiguous statutory provision.”
33In summary, in interpreting s. 10(2) of O.Reg. 282/98, its words must be read in their grammatical and ordinary sense harmoniously with the scheme of the Act, the object of the Act, and the intention of the legislature. Although there is a residual presumption in favour of the taxpayer, it only applies in the exceptional case where application of the ordinary principles of interpretation does not resolve any ambiguity in the meaning of this section.
Board’s Analysis
34In order for the Board to determine the correct property classification of the Subject Properties pursuant to the Act, the question the Board must decide is whether or not the units were “built pursuant to a building permit issued, on or after April 20, 2017.”
35The is no dispute amongst the parties that various multiple “staged” or “partial” building permits were issued over time including Full permits for each property. The Appellants take the position that these permits were necessary to construct the Subject Properties and specifically the Full permits - which authorized the construction of the units and the completion of the properties. At the hearing, both parties spent a considerable amount of time reviewing each of the permits in evidence as well as the associated construction drawings.
36The following table provides an overview of the building permit sequence issued by the Town of Ajax - Planning and Development Building Approvals for 65 Bayly Street West (Building A).
| Name of Document: | Date Issued: | Description of Work: | Special Conditions: |
|---|---|---|---|
| Building Permit 12 108209 | July 4, 2013 | New | Permit issued for “Shoring Only”, a separate permit is required for the construction of the building. |
| Building Permit 13 101971 RM | July 15, 2013 | New | Partial Permit Only: Construction shall not proceed beyond the foundation stage. |
| Building Permit 13 101971 RM | July 15, 2013 | New | Partial permit for above grade super-structure only, issued September 9, 2015*. Partial Permit Only: Construction shall not proceed beyond the building superstructure stage. |
| Building Permit 13 101971 RM | July 15, 2013 | New | Partial permit for above grade super-structure, mechanical and plumbing only, issued October 28, 2015*. Partial Permit Only: Construction shall not proceed beyond the building super-structure stage. |
| Building Permit 13 101971 RM | July 15, 2013 | New | FULL BUILDING PERMIT ISSUED OCTOBER 13, 2017* |
Note: These permits issued under the Special Conditions section of the July 15, 2013 building permit on each of the corresponding dates. (Underline emphasis added.)
37The following table provides an overview of the building permit sequence issued by the Town of Ajax - Planning and Development Building Approvals for 420 Harwood Avenue South (Building B).
| Name of Document: | Date Issued: | Description of Work: | Special Conditions: |
|---|---|---|---|
| Building Permit 16 103214 | July 8, 2016 | New | Permit issued for “Shoring Only”, a separate permit is required for the construction of the Building. |
| Building Permit 16 106883 | November 10, 2016 | New | Partial Permit for foundation only, issued November 10, 2016. Partial Permit Only: Construction shall not proceed beyond the foundation stage. |
| Building Permit 16 106883 | November 10, 2016 | New | Partial Permit extended to include below grade drains, issued December 9, 2016*. Partial permit for foundation only, issued November 10, 2016. Partial Permit Only: Construction shall not proceed beyond the foundation stage. |
| Building Permit 16 106883 | November 10, 2016 | New | Partial permit extended to include above grade superstructure, mechanical and plumbing systems, issued September 1, 2017*. Partial Permit Only: Construction shall not proceed beyond the superstructure, mechanical and plumbing stage. |
| Building Permit 16 106883 | November 10, 2016 | New | Full permit issued May 31, 2019*. |
Note: These permits issued under the Special Conditions section of the Nov 10, 2016 building permit on each of the corresponding dates. (Underline emphasis added.)
38The parties agree that the purpose of the Regulation was to encourage and accelerate the development of multi-residential property.
39The Regulation clearly and plainly requires that the new multi-residential property class consists of land… whose units have been built…pursuant to a building permit issued, on or after April 20, 2017.
40Upon review and consideration of the evidence and submissions provided by the parties, the Board makes the following determinations:
a. One or more permits (including partial permits and Full permits) were issued by the Chief Building Official, Town of Ajax, Planning and Building Approvals, for each of the Subject Properties.
b. In the case of each of the Subject Properties at least one permit (partial, Full, or Full Building permit) was issued after the key date in the Regulation of April 20, 2017.
c. In both cases, the Full permit was issued after the key date in the Regulation – April 20, 2017.
d. Partial permits are permits as defined in the relevant Town of Ajax By-law.
e. While there is no guarantee of subsequent permits being issued, without which a building project may not proceed to the next stage, or to completion, it is understood that upon compliance with all legal requirements, the chief building official is obliged to issue the building permit. Nonetheless, the subsequent permit is a necessity in order to proceed to the next stage including building completion. This is clearly indicated on the permits as reflected in the language – “Partial Permit Only: Construction shall not proceed beyond the [as referenced] building stage”. See above charts for further information.
41The Board notes that only the permits issued October 13, 2017 and May 31, 2019, respectively (i.e., both after April 20, 2017) are shown as the “Full” permits.
42Further, the Board notes that while the first building permit issued (identified as a “partial permit” under Special Conditions) for each property has an issue date, that each subsequent partial permit “attached to” or associated with the first permit has its own separate (later) issue date. It is the later issue date that is relevant to the subsequent partial permit reflecting the approval date for the relevant and next stage of construction. Otherwise and logically, no such subsequent partial permit is necessary.
43As a result of the above analysis of the evidence, the Board does not accept MPAC’s and the Municipality’s assertion that the first building permit issued (a partial permit as indicated by the language therein “Partial Permit Only: Construction shall not proceed beyond the foundation stage”) approved the construction of the entire building (see paragraph 3 and 4). Again, otherwise and logically, no subsequent permits are necessary. This is confirmed by the expert testimony at the hearing of both Mr. Vucicevich (for the Appellant) and Mr. McReelis (for the Municipality) where they each independently stated that construction could not proceed beyond the approved stage of the partial permit, and that the building and the residential units could not have been completed without the Full Permit.
44Prior to a final determination, the Board must consider the intention of the legislature and the context and purpose of the legislation to guide its reading of the Regulation, even though the Board considers the language clear and unambiguous in its meaning and the application of the facts.
45While the parties make reference to words and associated characterizations such as partial, initial, original, effective, and full in the context of a permit – the Regulation makes no such distinction, nor does it apply any such specificity. The Regulation is clear. The facts are clear. The residential units in question, have been built pursuant to a building permit issued on or after April 20, 2017.
46Section 10(2) of the Regulation provides that the “new multi-residential property class consists of land … whose units have been built…pursuant to a building permit issued…”. The requirement to qualify in the new multi-residential property class is limited by the words “pursuant to a building permit issued”. The legislature did not provide any further specificity e.g., initial, partial, full, final, etc. in the context of a building permit.
47The parties agree that the purpose of the new multi-residential property class is to encourage the development of new multi-family residential rental housing within the Province of Ontario. This is achieved by providing the incentive of a lower tax rate than that of the multi-residential property class. The legislature contemplated the scope of qualifying for the new multi-residential property class, in order to benefit from the lower tax rate, by setting out the conditions for eligibility.
48Provided that the conditions of the Regulation are met, a project qualifies within the new multi-residential property class. The legislature did not describe nor include any specific exclusions. For example, there could have been projects at various stages of the development process including design, planning, permitting, or construction. If these projects meet the eligibility conditions the Regulation, then they qualify for the new multi-residential classification. As stated above, there are no specific exclusions to the foregoing.
49A project that is already under various stages of development including potentially construction is not excluded from the new multi-residential property classification – provided that it meets the eligibility requirements stated in the Regulation. This is consistent with purpose and intent of the legislature – to encourage the development of multi-family residential units. The projects in question meet this objective.
50Finally, the Board distinguishes Magnum, cited by the Municipality, in that the question in that proceeding per paragraph 4 of the decision “turns on whether renovations to the properties that took place between 2012 and 2014 mean that the units were built, or converted from a non-residential use, pursuant to a building permit issued”. This is a different question than the one being addressed here.
Finding and Conclusion on the Issue
51The Board finds that the correct property class for each of the Subject Properties is New Multi-Residential (NT) for the respective taxation years in each case.
ORDER
52The Board orders that the correct property class for 61-73 Bayly Street West for the 2018-2023 taxation years is the New Multi-Residential (NT) property class, and that the correct property class for 420 Harwood Avenue South for the 2020-2023 taxation years is the New Multi-Residential (NT) property class.
53Given the prior agreement of the parties (see para 6 above) regarding the correct current values of the Subject Properties, the Board accepts and orders, pursuant to the various appeals listed, that the assessments of the Subject Properties be adjusted to reflect the agreed-upon values shown on the attached Schedules B and C.
"Christopher Voutsinas"
CHRISTOPHER VOUTSINAS
VICE-CHAIR
Assessment Review Board
Website: www.tribunalsontario.ca/arb
SCHEDULE “A"
| Appeal No | Roll Number | Address | Assessed Person | Year |
|---|---|---|---|---|
| 3512557 | 1805 040 006 24790 0000 | 61 to 73 BAYLY ST W | Medallion Developments (Bayly Square) A Limited | 2023 |
| 3488081 | 1805 040 006 24790 0000 | 61 to 73 BAYLY ST W | Medallion Developments (Bayly Square) A Limited | 2022 |
| 3443524 | 1805 040 006 24790 0000 | 61 to 73 BAYLY ST W | Medallion Developments (Bayly Square) A Limited | 2021 |
| 3402591 | 1805 040 006 24790 0000 | 61 to 73 BAYLY ST W | Medallion Developments (Bayly Square) A Limited | 2020 |
| 3422826 | 1805 040 006 24790 0000 | 61 to 73 BAYLY ST W | Medallion Developments (Bayly Square) A Limited | 2020 |
| 3422827 | 1805 040 006 24790 0000 | 61 to 73 BAYLY ST W | Medallion Developments (Bayly Square) A Limited | 2020 |
| 3422828 | 1805 040 006 24790 0000 | 61 to 73 BAYLY ST W | Medallion Developments (Bayly Square) A Limited | 2020 |
| 3355437 | 1805 040 006 24790 0000 | 61 to 73 BAYLY ST W | Medallion Developments (Bayly Square) A Limited | 2019 |
| 3385574 | 1805 040 006 24790 0000 | 61 to 73 BAYLY ST W | Medallion Developments (Bayly Square) A Limited | 2019 |
| 3385576 | 1805 040 006 24790 0000 | 61 to 73 BAYLY ST W | Medallion Developments (Bayly Square) A Limited | 2019 |
| 3385577 | 1805 040 006 24790 0000 | 61 to 73 BAYLY ST W | Medallion Developments (Bayly Square) A Limited | 2019 |
| 3385571 | 1805 040 006 24790 0000 | 61 to 73 BAYLY ST W | Medallion Developments (Bayly Square) A Limited | 2018 |
| 3385572 | 1805 040 006 24790 0000 | 61 to 73 BAYLY ST W | Medallion Developments (Bayly Square) A Limited | 2018 |
| 3385573 | 1805 040 006 24790 0000 | 61 to 73 BAYLY ST W | Medallion Developments (Bayly Square) A Limited | 2018 |
| 3385575 | 1805 040 006 24790 0000 | 61 to 73 BAYLY ST W | Medallion Developments (Bayly Square) A Limited | 2018 |
| 3519765 | 1805 040 006 24781 0000 | 420 HARWOOD AVE S | Medallion Developments (Bayly Square) B Limited | 2023 |
| 3519766 | 1805 040 006 24781 0000 | 420 HARWOOD AVE S | Medallion Developments (Bayly Square) B Limited | 2023 |
| 3519767 | 1805 040 006 24781 0000 | 420 HARWOOD AVE S | Medallion Developments (Bayly Square) B Limited | 2023 |
| 3519768 | 1805 040 006 24781 0000 | 420 HARWOOD AVE S | Medallion Developments (Bayly Square) B Limited | 2023 |
| 3514760 | 1805 040 006 24781 0000 | 420 HARWOOD AVE S | Medallion Developments (Bayly Square) B Limited | 2023 |
| 3512444 | 1805 040 006 24781 0000 | 420 HARWOOD AVE S | Medallion Developments (Bayly Square) B Limited | 2023 |
| 3512464 | 1805 040 006 24781 0000 | 420 HARWOOD AVE S | Medallion Developments (Bayly Square) B Limited | 2023 |
| 3514759 | 1805 040 006 24781 0000 | 420 HARWOOD AVE S | Medallion Developments (Bayly Square) B Limited | 2023 |
| 3488163 | 1805 040 006 24781 0000 | 420 HARWOOD AVE S | Medallion Developments (Bayly Square) B Limited | 2022 |
| 3488164 | 1805 040 006 24781 0000 | 420 HARWOOD AVE S | Medallion Developments (Bayly Square) B Limited | 2022 |
| 3514757 | 1805 040 006 24781 0000 | 420 HARWOOD AVE S | Medallion Developments (Bayly Square) B Limited | 2022 |
| 3514758 | 1805 040 006 24781 0000 | 420 HARWOOD AVE S | Medallion Developments (Bayly Square) B Limited | 2022 |
| 3443180 | 1805 040 006 24781 0000 | 420 HARWOOD AVE S | Medallion Developments (Bayly Square) B Limited | 2021 |
| 3443448 | 1805 040 006 24781 0000 | 420 HARWOOD AVE S | Medallion Developments (Bayly Square) B Limited | 2021 |
| 3421155 | 1805 040 006 24781 0000 | 420 HARWOOD AVE S | Medallion Developments (Bayly Square) B Limited | 2020 |
| 3421156 | 1805 040 006 24781 0000 | 420 HARWOOD AVE S | Medallion Developments (Bayly Square) B Limited | 2020 |
| 3421157 | 1805 040 006 24781 0000 | 420 HARWOOD AVE S | Medallion Developments (Bayly Square) B Limited | 2020 |
| 3421158 | 1805 040 006 24781 0000 | 420 HARWOOD AVE S | Medallion Developments (Bayly Square) B Limited | 2020 |
| 3427355 | 1805 040 006 24781 0000 | 420 HARWOOD AVE S | Medallion Developments (Bayly Square) B Limited | 2020 |
| 3427356 | 1805 040 006 24781 0000 | 420 HARWOOD AVE S | Medallion Developments (Bayly Square) B Limited | 2020 |
SCHEDULE “B”
BUILDING A (ROLL NO. 18 05 040 006 24790 0000)
FINAL AGREED-UPON VALUES IF NEW MULTI-RESIDENTIAL (NT) CLASSIFICATION IS DETERMINED TO BE CORRECT
| Appeal Nos. | Sec. | Effective Date | Multi-Residential (MT) From | Multi-Residential (MT) To | New Multi-Residential (NT) From | New Multi-Residential (NT) To | Commercial New Const. (XT) From | Commercial New Const. (XT) To | Total From | Total To |
|---|---|---|---|---|---|---|---|---|---|---|
| 3385571 | 33 | 1-Apr-18 | 48,689 | 0 | 0 | 1,695,000 | 0 | 0 | 48,689 | 1,695,000 |
| 3385572 | 33 | 1-Apr-18 | 5,910,311 | 0 | 0 | 10,885,000 | 0 | 0 | 5,910,311 | 10,885,000 |
| 3385575 | 33 | 15-Jul-18 | 0 | 0 | 0 | 0 | 777,000 | 2,034,000 | 777,000 | 2,034,000 |
| 3385573 | 33 | 1-Oct-18 | 19,994,000 | 0 | 0 | 21,827,000 | 0 | 0 | 19,994,000 | 21,827,000 |
| 3355437 | 40 | 1-Jan-19 | 5,565,000 | 0 | 0 | 1,695,000 | 0 | 0 | 5,565,000 | 1,695,000 |
| 3385574 | 33 | 1-Jan-19 | 56,856,000 | 0 | 0 | 66,449,000 | 0 | 0 | 56,856,000 | 66,449,000 |
| 3385576 | 33 | 1-Jan-19 | 0 | 0 | 0 | 0 | 29,000 | cancel | 29,000 | cancel |
| 3385577 | 33 | 1-Jan-19 | 0 | 0 | 0 | 0 | 748,000 | 2,034,000 | 748,000 | 2,034,000 |
| 3402591 | 40 | 1-Jan-20 | 62,421,000 | 0 | 0 | 68,144,000 | 777,000 | 2,034,000 | 63,198,000 | 70,178,000 |
| 3422826 | 34 | 1-Jul-20 | 0 | 0 | 0 | 0 | 1,400 | cancel | 1,400 | cancel |
| 3422827 | 34 | 1-Jul-20 | 0 | 0 | 0 | 0 | 737,000 | 1,933,000 | 737,000 | 1,933,000 |
| 3422828 | 34 | 1-Aug-20 | 0 | 0 | 0 | 0 | 1,018,000 | 2,666,000 | 1,018,000 | 2,666,000 |
| 3443524 | 40 | 1-Jan-21 | 64,176,600 | 0 | 0 | 70,060,000 | 2,533,400 | 6,633,000 | 66,710,000 | 76,693,000 |
| 3488081 | 40 | 1-Jan-22 | 64,176,600 | 0 | 0 | 70,060,000 | 2,533,400 | 6,633,000 | 66,710,000 | 76,693,000 |
| 3512557 | 40 | 1-Jan-23 | 64,176,600 | 0 | 0 | 70,060,000 | 2,533,400 | Change to CT 6,633,000 | 66,710,000 | 76,693,000 |
SCHEDULE “C”
BUILDING B (ROLL NO. 18 05 040 006 24781 0000)
FINAL AGREED-UPON VALUES IF NEW MULTI-RESIDENTIAL (NT) CLASSIFICATION IS DETERMINED TO BE CORRECT
| Appeal Nos. | Sec. | Effective Date | Multi-Residential (MT) From | Multi-Residential (MT) To | New Multi-Residential (NT) From | New Multi-Residential (NT) To | Commercial New Const. (XT) From | Commercial New Const. (XT) To | Total From | Total To |
|---|---|---|---|---|---|---|---|---|---|---|
| 3421155 | 34 | 1-Feb-20 | 123,000 | 0 | 0 | 1,515,000 | 0 | 0 | 123,000 | 1,515,000 |
| 3421156 | 34 | 1-Feb-20 | 123,000 | 0 | 0 | 1,515,000 | 0 | 0 | 123,000 | 1,515,000 |
| 3421157 | 34 | 1-Feb-20 | 8,387,000 | 0 | 0 | 11,367,000 | 0 | 0 | 8,387,000 | 11,367,000 |
| 3421158 | 34 | 1-Feb-20 | 8,387,000 | 0 | 0 | 11,367,000 | 0 | 0 | 8,387,000 | 11,367,000 |
| 3427355 | 34 | 1-Oct-20 | 19,749,000 | 0 | 0 | 21,858,000 | 0 | 0 | 19,749,000 | 21,858,000 |
| 3427356 | 34 | 1-Oct-20 | 19,749,000 | 0 | 0 | 21,858,000 | 0 | 0 | 19,749,000 | 21,858,000 |
| 3443180 | 40 | 1-Jan-21 | 65,038,000 | 0 | 0 | 71,985,000 | 0 | 1,457,000 | 65,038,000 | 73,442,000 |
| 3443448 | 40 | 1-Jan-21 | 65,038,000 | 0 | 0 | 71,985,000 | 0 | 1,457,000 | 65,038,000 | 73,442,000 |
| 3488163 | 40 | 1-Jan-22 | 65,038,000 | 0 | 0 | 71,985,000 | 0 | 1,457,000 | 65,038,000 | 73,442,000 |
| 3488164 | 40 | 1-Jan-22 | 65,038,000 | 0 | 0 | 71,985,000 | 0 | 1,457,000 | 65,038,000 | 73,442,000 |
| 3512444 | 40 | 1-Jan-23 | 65,038,000 | 0 | 0 | 71,985,000 | 0 | Change to CT 1,457,000 | 65,038,000 | 73,442,000 |
| 3512464 | 40 | 1-Jan-23 | 65,038,000 | 0 | 0 | 71,985,000 | 0 | Change to CT 1,457,000 | 65,038,000 | 73,442,000 |
| 3514757 | 33 | 03-Nov-22 | 0 | 0 | 0 | 0 | 375,000 | 0 | 375,000 | 0 |
| 3514758 | 33 | 03-Nov-22 | 0 | 0 | 0 | 0 | 375,000 | 0 | 375,000 | 0 |
| 3514759 | 33 | 01-Jan-23 | 0 | 0 | 0 | 0 | 1,550,000 | 0 | 1,550,000 | 0 |
| 3514760 | 33 | 01-Jan-23 | 0 | 0 | 0 | 0 | 1,550,000 | 0 | 1,550,000 | 0 |
| 3519765 | 34 | 28-Jun-23 | 125,020 | 0 | 0 | 0 | 0 | 0 | 125,020 | 0 |
| 3519766 | 34 | 28-Jun-23 | 125,020 | 0 | 0 | 0 | 0 | 0 | 125,020 | 0 |
| 3519767 | 34 | 28-Jun-23 | 0 | 0 | 0 | 0 | 2,980 | 0 | 2,980 | 0 |
| 3519768 | 34 | 28-Jun-23 | 0 | 0 | 0 | 0 | 2,980 | 0 | 2,980 | 0 |