Holiday Luggage Mfg. Co. Inc. v. The Queen, 86 DTC 6601, [1987] 1 CTC 23 (FCTD) -- summary under Paragraph 256(1)(d)

Father and son each owned substantially all the shares of a CCPC, and 30% of the shares of a U.S. corporation. Joyal, J. held that the two CCPC's were not associated because foreign corporations were intended to be excluded from the category of corporations for the purposes of that section. The definition of "corporation" in s. 248(1) was not conclusive.