CRA indicates that a s. 184(3) excess dividend election deems the elected-upon amount to retroactively be income even if it is still unpaid
The s. 184(3)(b) excess dividend election is made respecting the amount of the original dividend that was payable. S. 184(3)(d) deems the shareholder to have received the excess dividend. CRA confirmed that the effect of this is that the excess portion of the dividend becomes taxable to the shareholder as of the time of the original dividend declaration, even if it still remains unpaid.
CRA had already notified Finance of this anomaly.