3 December 2015 External T.I. 2015-0593941E5 F - Allocation of the safe income on hand -- summary under Paragraph 55(2.1)(b)

CRA declined to express a view as to whether an $8,000 reduction in an accrued capital gain of $120,000 was significant. A $50,000 dividend received by two Holdcos from Opco (with no indication of the total FMV of all the shares) would be considered to be significant.