In a December 8, 2015 French Technical Interpretation (2015- 0610921E5, Labarre, Sylvie, CPA, CA), CRA commented on whether association would apply to a situation where the controlling shareholder turns 18 years of age in the corporation’s fiscal year.
In the situation where the child does not manage the business, CRA opined that Subsection 256(1.3) would apply in the corporate fiscal year where the age of 18 is obtained because the child would have been under 18 at some point in that fiscal year. Being associated at any time in the year means the consequences of association apply for the entire fiscal year.
For further information see VTN Monthly Tax Update Seminar, Issue No. 417