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.

whether the corporations were associated at any time in the year

Subsection 256(1.3) notes that the capital stock of a child who is under 18 years of age is deemed to be owned by the child’s parents for association purposes unless the child manages the business and affairs of the corporation without a significant degree of influence by the parent.

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.