Upon conversion to a functional currency, the CDA must also be converted irrespective of CDA activity

Since the capital dividend account of a Canadian corporation, which has made a functional currency election, is relevant to its "Canadian tax results" (i.e., whether it is subject to Part III tax), it is required to convert its CDA to the functional currency as at the end of the Canadian currency year preceding its first functional currency year – irrespective of whether it actually paid a capital dividend.

Neal Armstrong.  Summary of 20 September 2013 T.I. 2012-0471261E5 under s. 261(7)(h).