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Bjoern Hoehrmann wrote
>    XML 1.0 SE says: "An element with no content is said to be empty".
> Does the following fragment have any content?
>   <elem><![CDATA[]]></elem>
Yes it does have content.  This is quite clear if you look at the grammar
for "content":

      [43]  content  ::=   CharData? ((element | Reference | CDSect | PI |
Comment) CharData?)*

Your content clearly contains a CDSect.  The fact that the CDSect has no
data is not relevant to the production.

> The Recommendation further reads: "The representation of an empty
> element is either a start-tag immediately followed by an end-tag, or an
> empty-element tag". This is true for the fragment in it's canonical
> representation.

True, but then you could argue the same for this:-
<elem><!-- this isn't empty unless the comment is removed --></elem>

Or this:-
<!ENTITY null "">