CRA indicates that there is an immediate CDA addition for a non-redemption dividend subject to s. 55(2)
S. 55(2)(c) deems most dividends that did not arise on a share redemption and to which s. 55(2) applies to be gains “for the year,” without specifying when in the year the deemed gains occurred. In a reversal of the result in 2011-0412131C6 (which dealt with somewhat different statutory wording), CRA has now indicated that a gain under s. 55(2)(c) is deemed to be realized at the time of the payment of the dividend, with the result that there is an addition to the capital dividend account at that time rather than only on completion of the year.
Neal Armstrong. Summary of 21 November 2017 CTF Annual Conference Roundtable, Q.4 under s. 55(2)(c).