CRA applies Consolidated Holding to the related corporation rules

CRA essentially followed Consolidated Holding (which, strictly speaking, dealt with the associated corporation rules) in finding that where one corporation is controlled by A and B, as trustees of a trust and another corporation is controlled by A and B in their own right (not as trustees), the two corporations are related pursuant to s. 251(2)(c)(i) (two corporations controlled by the same group of persons).

Neal Armstrong. Summary of 20 June 2023 STEP Roundtable, Q.8 under s. 251(2)(c)(i).