22 June 2023 External T.I. 2018-0746741E5 F - Eligible dividend allocation -- summary under Subsection 104(13)

A discretionary trust received an eligible dividend in a year and immediately allocated and distributed it to a beneficiary; and later in the same year, received an ordinary (non-eligible) dividend which it immediately allocated and distributed to a second beneficiary, also in accordance with the discretions accorded by the trust deed. CRA found that the two respective dividends could be designated under s. 104(19) exclusively to the respective beneficiaries rather than being required to be designated on a pro rata basis.