No. The relationship must be one the regulations recognize, proven by ownership and control records showing the same owners hold both entities in qualifying proportions. Related individuals owning different shares of two companies is not automatically an affiliate relationship.
Prove common ownership and control, not kinship
A qualifying relationship exists where one entity owns and controls the other, or where the same parent or the same group of individuals owns and controls both, each individual holding approximately the same share and proportion in each. That test is about numbers on a share register. Two brothers who own a Québec company 60/40 and a U.S.
company 40/60 may believe the businesses are one group, but the proportions differ and the file needs to explain how control is actually exercised. Gather the incorporation documents, the current cap tables and any shareholder or voting agreements for both companies, then draw the ownership as a diagram. If the answer is that the structure does not fit, the group can consider adjusting ownership before filing, but the change must be real and documented, and recent changes will be examined for whether the entities genuinely operate as a group.