# Association question
**URL:** https://www.protaxcommunity.com/t/association-question/11773
**Category:** Tax Topics
**Created:** [January 23, 2026, 9:57pm UTC](https://www.protaxcommunity.com/t/association-question/11773 "2026-01-23T21:57:47Z")
**Posts on this page:** 6
**Page:** 1
### Author:  [@dongminkun](https://www.protaxcommunity.com/u/dongminkun)
#### Post date: [January 23, 2026, 9:57pm UTC](https://www.protaxcommunity.com/t/association-question/11773/1 "2026-01-23T21:57:47Z")
Opco has 2 Holdcos and the shares of each Holdco are owned by 2 different individuals (unrelated), 50-50% respectively. In this case, the 3 corporations are not association (ignoring de facto control)?
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### Author:  [@iain.fyffe](https://www.protaxcommunity.com/u/iain.fyffe)
#### Post date: [January 23, 2026, 10:12pm UTC](https://www.protaxcommunity.com/t/association-question/11773/2 "2026-01-23T22:12:56Z")
Not enough information. You didn’t state whether the two holdcos had equal shareholdings in Opco. Also de facto control can be a question.
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### Author:  [@dongminkun](https://www.protaxcommunity.com/u/dongminkun)
#### Post date: [January 23, 2026, 10:26pm UTC](https://www.protaxcommunity.com/t/association-question/11773/3 "2026-01-23T22:26:41Z")
Just updated my question. Thank you
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### Author:  [@jeffliu](https://www.protaxcommunity.com/u/jeffliu)
#### Post date: [January 24, 2026, 12:49am UTC](https://www.protaxcommunity.com/t/association-question/11773/4 "2026-01-24T00:49:31Z")
You have to look at each and every possible scenario to determine, no one can do that for you with all your factual information. [https://www.canada.ca/en/revenue-agency/services/forms-publications/publications/it64r4-consolid/archived-corporations-association-control.html](https://www.canada.ca/en/revenue-agency/services/forms-publications/publications/it64r4-consolid/archived-corporations-association-control.html)
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### Author:  [@Nezzer](https://www.protaxcommunity.com/u/Nezzer)
#### Post date: [January 25, 2026, 3:18am UTC](https://www.protaxcommunity.com/t/association-question/11773/5 "2026-01-25T03:18:52Z")
Probably not associated, but if the 2 individuals are friends, such that they discuss their business decisions together, and possibly make decisions that benefit each other, they would be considered non-arms-length, which would make the whole group associated (unless they designate the Opco as a CCPC “third” corp with no business limit).
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### Author:  [@RRAccounting](https://www.protaxcommunity.com/u/RRAccounting)
#### Post date: [January 25, 2026, 9:03pm UTC](https://www.protaxcommunity.com/t/association-question/11773/6 "2026-01-25T21:03:53Z")
This is very complex, say a minor has a father and mother that are not married, so mother and father are not associated, but they are each related and associated with the minor