CRA indicates that a discretionary family trust is required to make a pro rata allocation of safe income respecting a dividend distributed to its beneficiaries

CRA indicated that when a discretionary family trust distributes a dividend received from Opco to a corporate and an individual beneficiary (with a s. 104(19) designation being made), “the safe income on hand associated with the dividend would be allocated on a pro rata basis amongst the portions of the dividend received by the corporate and individual beneficiaries,” rather than the trustees being permitted to allocate all of safe income to the dividend received by the corporate beneficiary.

Neal Armstrong. Summary of 27 January 2020 External T.I. under s. 55(2.1)(c).