CRA indicates that a late s. 83(3) election causes a retroactive increase to the CDA of the corporate recipient of the dividend
CRA indicated that a late but valid capital dividend election retroactively validates the dividend, so that the recipient of the dividend thereby has an addition to its capital dividend account at the time of the receipt of the dividend.
Neal Armstrong. Summary of 30 August 2017 External T.I. 2017-0718311E5 F under s. 83(3).