20 November 2015 External T.I. 2014-0539951E5 - Foreign Currency Denominated Dividends -- summary under Subsection 89(14)

Citing Banner Pharmacaps, CRA considered that a dividend does not “arise” for s. 261(2) purposes until it is paid (rather than declared) so that its amount, including for eligible dividend designation purposes, is translated using the spot rate on the payment date.