Respecting queries on how to calculate the safe income on hand ("SIOH") of a CCPC (Corporation A) that recognized income on a lumpy basis when it made progress billings, CRA noted that the SIOH attributable to a particular share may be based on a holding period that contains two stub periods (the period from the date of acquisition of the share to the first year-end; and the period from the last year-end to the safe income determination time) and that:
[T]he calculation of the SIOH in respect of the "stub" period should generally not be calculated as if an end of a taxation year has occurred at the SIDT but, rather, in proportion to the number of days of the "stub" period in relation to the total number of days in the particular taxation year of Corporation A.
In addition, we agree with your position that the calculation of the SIOH attributable to the shares of the capital stock of Corporation A in respect of a "stub" period must generally take into account the income taxes payable by the corporation and attributable to the "stub" period.