A related group can consist of corporations whose respective controlling shareholders are not all related to each other

A is related to his wife’s brother (B), and B is related to his wife’s parent (C), but A is unrelated to C. If A, B and C each holds 1/3 of the shares of Dco through his respective holdco (Aco, Bco or Cco), each of Aco, Bco and Cco will be considered to be related to Dco (given inter alia that Aco and Cco is each related to Bco and they thus are deemed to be related to each other), and Dco will also be considered to be related to a subsidiary of Aco.

Neal Armstrong. Summary of October 2014 APFF Roundtable, Q. 17, 2014-0538071C6 F under s. 251(3).