CRA indicates that most (e.g., calendar-year) corporations should continue to use the old (pre-Update) CRA positions in computing safe income for 2023 and prior taxation years

In its 2023 Safe Income Paper, CRA indicated that its changes in position would apply prospectively to calculations of safe income for taxation years beginning after November 28, 2023.

CRA now confirmed that this meant that “a corporation's safe income must be calculated for each taxation year in accordance with the CRA positions applicable to that year.” For example, if a calendar-year corporation began a series of transactions in September 2025 that would include the payment of a dividend to which s. 55(2) would apply, it would determine its safe income as of September 2025 by calculating its safe income for each of its taxation years up to and including its 2023 taxation year using its old positions, and for its 2024 and 2025 taxation years using its new positions.

Neal Armstrong. Summary of 9 October 2025 APFF Roundtable, Q.8 under s. 55(2.1)(c).