As can be seen in the case of Minister of National Revenue v. Consolidated Holding, 1971 CanLII 191 (SCC),  S.C.R. 419, certain statutes do contain the words “controlled by the same person or group of persons” such as paragraph 39(4)(b) of the Income Tax Act, RSC 1952, c 148, as amended which deals with whether two corporations are associated. It provides as follows: 39(4) For the purpose of this section, one corporation is associated with another in a taxation year if, at any time in the year, (…) (b) both of the corporations were controlled by the same person or group of persons, (…)
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