18 July 2006 External T.I. 2005-0162181E5 F - Subsection 74.4(2) -- summary under Paragraph 74.4(2)(a)

CRA indicated that Ms. B (the common law partner of Mr. A) would be a specified shareholder of Aco (held by her and Mr. A as to 9% and 91% of the common shares, respectively) if she also wholly-owned Bco (a related corporation to Aco) – but not if she did not own any shares of a corporation related to Aco. CRA acknowledged that the first result seemed anomalous.