Usually that will give you the top view, but there's no guarantee that it's visible to the user. It could be off the screen, have an alpha of 0.0, or could be have size of 0x0 for example.
It could also be that the keyWindow has no subviews, so you should probably test for that first. This would be unusual, but it's not impossible.
UIWindow is a subclass of UIView, so if you want to make sure your notification is visible to the user, you can add it directly to the keyWindow using addSubview:
and it will instantly be the top most view. I'm not sure if this is what you're looking to do though. (Based on your question, it looks like you already know this.)