The requirement for transactions to be “related” may limit the scope of the “series” concept

S. 248(10) deems a series to include "any related transactions" completed "in contemplation" of the series.  Unless the "related" branch is to be ignored (see Placer Dome), it restricts at least somewhat the scope of the series concept otherwise resulting from the broad interpretation of "in contemplation of" in Copthorne.

Alarie and Lockhart also advert to the Wittgenstein concept of "family resemblances" (analogizing to family members who "despite having no single set of features in common… may quite visibly belong to the same family,") and suggest that in order for transactions to be assimilated to a series they "must bear a family resemblance to those that Parliament could reasonably be considered to have had in mind in invoking the series concept as a means of anti-avoidance."

Neal Armstrong.  Summary of Benjamin Alarie and Julia Lockhart, "The Importance of Family Resemblance: Series of Transactions After Copthorne", Canadian Tax Journal (2014) 62:1, 273-99 under s. 248(10).