The CRA accepts that a safe income dividend paid from Opco to a trust-shareholder, which then allocates the dividend to Holdco, one of the trust’s beneficiaries, will be added to Holdco’s safe income. Technical interpretation 2014-0538061C6 dated October 10, 2014, summarized in Manu Kakkar and Marissa Halil, “Corporate Beneficiary Can Add to Its Safe Income on Hand” (July 2015) 15:1 Tax for the Owner-Manager 7.
