A specified corporation in relation to the issuing corporation agrees to acquire shares for a specified amount within 60 days, but in fact the acquisition cannot be completed until the 61st day.
After noting that the "particular time" for determining taxability under Parts IV.1 and VI.1 is the time of receipt or payment of the dividend, respectively, CRA stated (TaxInterpretations translation):
Consequently, at the time when the corporation pays or receives a dividend, as the case may be, the relieving provisions of subparagraphs (f)(i) or (f)(ii) of the definition of TPS or those of clauses (a)(i)(A) or (a)(i)(B) of the definition of STPS may or may not be applicable in determining if the share on which the dividend is paid or received constitutes a TPS and/or a STPS, in accordance with the circumstances.
CRA then indicated that the determination of this question would require a review of all the facts and circumstances bearing on the particular situation.