Having regard to the concern that the safe-income determination time is no later than the time immediately before the earliest dividend paid as part of a “series,” which is broadly defined in s. 248(10) and Copthorne, CRA stated:
In a recent ruling, the CRA took the view that regular, recurring annual dividends would not, in the circumstances of the ruling request, be part of a series of transactions. Accordingly, a ruling confirmed that the safe income determination time in respect of the first and second annual dividends will be immediately before each such dividend.
CRA went on to confirm 2016-0633961E5 (respecting recapture of depreciation realized on sale before safe-income determination time being included in safe income.)