Mr, X wholly-owned ACo and his wife, Mrs. X, wholly-owned BCo. ACo and BCo were not associated. Would ACo and BCo be required to aggregate their taxable capital employed in Canada for the purposes of the formula reduction in their business limit pursuant to s. 125(5.1)(a)? CRA responded:
[A]s ACo and BCo are not associated in the taxation year, the two corporations would not be required to aggregate their taxable capital employed in Canada for the purpose of paragraph 125(5.1)(a) … .