Question
(A) Michelle owns 100% of the common shares of Drake Co, Ltd. (DCL), and Bob owns 70% of the common shares of Ji Co. Ltd.
(A) Michelle owns 100% of the common shares of Drake Co, Ltd. (DCL), and Bob owns 70% of the common shares of Ji Co. Ltd. (JCL). The other 30% of the common shares of JCL are owned by DCL. Bob is married to Michelle's granddaughter.
(B) Katie and Alexis are siblings who each own 50% of the common shares of Christopher Jericho Enterprises Ltd. (CJEL). Rachel and Anna each own 40% of the common shares of Goliath Mfg. Ltd. (GML). The other 20% of the common shares of GML are owned 10% each by Katie and Alexis. Rachel and Anna are adult daughters of Katie and Alexis, respectively. The parents, who have operated their financial advice business for many years, were providing needed outside funding of their daughters' manufacturing business through the parents 20% share ownership. The parents take no part in the management of their daughters business, since the parents have no expertise related to the business of GML.
(C) Kristen owns all of the common shares of Stewart James Retailing Ltd. (SJRL), and 75% of the common shares of Cowboys Investments Ltd. (CIL). The other 25% of CIL common shares are owned by unrelated persons. Also, CIL owns all of the common shares of George Mfg. Ltd. (GML). Henry owns 65% of the common shares of Robert Wholesalers Ltd. (RWL). The other 35% of the common shares of RWL are owned by SJRL. Henry is married to Kristens niece. The 35% ownership of SJRL in RWL was to provide RWL with some needed start-up financing.
Required: Indicate whether the corporations in each of the above situations are associated. Explain in your own words the reasoning behind your conclusion, based on the conditions for association contained in any provision of the legislation that you choose to apply. You are required to use section references from the Canadian Income Tax Act in your response.
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