CRA states that the TFSB of FA should be translated into Canadian dollars under s. 55(5)(d) at the safe income determination time

S. 55(5)(d) deems the safe income of an FA wholly-owned by Canco to be its tax free surplus balance (or its shares’ fair market value, if lower). Where Canco pays a dividend to its shareholder (Can Holdco) at a time subsequent to the safe income determination time (SIDT), CRA considers that the TFSB of FA should be translated into Canadian dollars at the SIDT rather than on the dividend payment date.

Neal Armstrong. Summary of 3 December 2019 CTF Roundtable, Q.3 under s. 55(5)(d)(i).