26 October 2010 External T.I. 2010-0363341E5 - Related corporations -- summary under Paragraph 251(5)(a)

Grandfather has 42% of the voting rights for Aco and his son has the balance of 58% of the voting rights. Grandchildren (who thus are related to Grandfather but are nephews of his son and, thus, unrelated to the son) own Bco. Becasue Grandfather controls Aco alone, it follows that Aco is not controlled by a related group, so that Aco and Bco are not related under s. 251(2)(c)(v). "Our position is based on the understanding that the comments in the Southside Car Market decision apply even in situations where the shareholders of a corporation are related persons...."