CRA found that an estate's holding of a debt claim to essentially all the NAV of an investment company was mostly irrelevant to de facto control

Although IT-64R4, para. 23 indicates that the holding of a large demand note is relevant to de facto control, CRA found in an internal technical interpretation (referenced, with a redacted document number, in a subsequent APFF Round Table) that this factor was "of little importance ... where the debt represented virtually all the net value of a corporation but all its assets consisted of readily marketable securities which could serve to repay the debt held by an estate without imperiling its investment operations."

Neal Armstrong.  Summary of 11 October 2013 APFF Round Table, Q. 4, 2013-0493651C6 F under s. 256(5.1).