Miller, The Estate of Carl Edward v. The Queen, 2002 DTC 1228 (TCC) -- summary under Subsection 256(5.1)

An order of the District Court of Ontario that there be no administration or distribution of an estate pending a decision of the widow of the deceased as to whether she wanted to proceed with the election under s. 5(2) of the Family Law Act (Ontario) to take under the will neither deprived the estate of control of three corporations that had been controlled by the deceased nor gave it to her. She had a rather limited right to veto some of the acts of administration or distribution but she could not elect directors nor could she influence the way in which the directors went about running the day-to-day affairs of the three corporations. Accordingly, the estate controlled directly or indirectly in any manner whatever the corporations for purposes of former s. 85(4).