29 January 2001 Internal T.I. 2000-0062827 F - Placement admissible - conjoint de fait -- summary under Connected Shareholder

The RRSPs of Mr. A and Ms. B each acquired a percentage (e.g., 8%?) of the shares of a cooperative corporation (with the balance of the shares held by unrelated persons) when, in the case of the second acquisition, they had been living in a conjugal relationship for less than 12 months. Subsequently, they began living in a conjugal relationship, and married. After discussing the extended meaning of spouse in s. 252(4)(a), the Directorate indicated that if they had no children, then immediately after the RRSP share acquisitions, they were not persons not dealing with each other at arm’s length under s. 252(1)(a), so that only on those grounds they would not be connected shareholders. However, it was a factual question whether they were not dealing with each other under s. 252(1)(c).