Must the advance authorization (described in s. 83(3)(c)) by the directors be made before the declaration of the dividend or merely before the late election? CRA responded:
The condition set out in paragraph 83(3)(c) is satisfied when the directors or other person or persons legally entitled to administer the affairs of the corporation have, before the time the election is made, authorized the election to be made.
CRA then referred to Folio S3-F2-C1, para. 1.21.