It may be imprudent to distribute amounts from an FA as a single dividend

The Reg. 59071(2)(b) election to have a dividend come out of pre-acquisition surplus (i.e., as an ACB reduction), rather than out of other surplus, can only be made on a “whole” dividend. Accordingly, given uncertainties as to surplus balances, foreign affiliate distributions often prudently should be paid out as multiple dividends, so that there can be later flexibility as to which dividends, if any, will be elected upon.

Neal Armstrong. Summary of Clara Pham, “Paying FA Dividends When Surplus Balances are Unclear,” Canadian Tax Focus, Vol. 7, No. 1, February 2017, p. 2 under Reg. 5901(2)(b).