After indicating, regarding a debenture that was convertible into shares of the CCPC issuer by the holder (Lenderco) in order to safeguard the creditor rights of Lenderco, that the phrase "controlled, directly or indirectly in any manner whatever" referred to de jure in addition to de facto control under subsection 256(5.1), CRA responded to a further question as to whether s. 256(6) only has the effect of deeming a corporation not to be controlled de jure and has no effect on "controlled, directly or indirectly in any manner whatever," so that both s. 256(6) and 256(3) would not cover de facto control by a creditor for the purposes of the definition of "Canadian-controlled private corporation", CRA stated:
[W]here it is determined that all of the conditions for the application of that subsection are met, the controlled corporation is deemed not to have been controlled in law or fact by the controller at the particular time.