CRA indicates that its position, that s. 83(2) elections and resolutions must specify dollar amounts, extends to s. 84(3) deemed dividends

9 October 2025 APFF Roundtable, Q.11 stated in relation to a cash capital dividend declared and paid by a vendor before the post-closing adjustments had been finalized:

The CRA's position, as stated in Technical Interpretation 2020-0852211C6, remains that, generally, the amount of the dividend designated under the election provided for in subsection 83(2) must be stated on Form T2054 and in the resolution authorizing that election in order for it to be considered valid, regardless of whether the election is filed within the prescribed time limits, or late and accompanied by the payment of the penalty established under subsection 83(4).

At the 2025 CTF Roundtable, CRA briefly indicated that this same position applied to an s. 84(3) deemed dividend whose exact amount was subject to post-closing adjustments (and where the authorizing corporate resolution was to refer to a formula taking any such adjustments into account).

Neal Armstrong. Summary of 2 December 2025 CTF Roundtable, Q.14 under s. 83(2).