CRA demonstrates the repeated application of ss. 251(2)(b)(ii) and (iii) to relate two corporations

CRA discussed how a repeated application of ss. 251(2)(b)(ii) and (iii) would establish that a corporation (Opco), owned equally by Father and Uncle, was related to a corporation (Newco), owned equally by five holding companies.

The first holding company was owned equally by the son and daughter-in-law of Father. Each of two of the holding companies was wholly-owned by one of the two brothers of the daughter-in-law. One of the holding companies was owned by the brother of the son, and the fifth was owned by an unrelated individual.

As usual, you can go to the linked summary for a more detailed discussion.

Neal Armstrong. Summary of 3 June 2025 External T.I. 2025-1064821E5 F under s. 251(2)(b)(iii).