17 February 2010 Internal T.I. 2009-0348461I7 F - Transfert d'une PCMC à une société mère -- summary under Paragraph 10(x)

After a subsidiary (“Imageco”) of a Canadian-controlled private corporation (“Canco”) produced a film and DVD (the "CFVPs"), being Canadian film or video productions for which Imageco received the film and video production tax credit, it transferred the CFVPs to Canco. The Directorate noted that “for Canco, the CFVPs could be depreciable property in Class 10(x).” The summary stated:

The cost to Canco of acquiring CFVPs is not limited to the production costs of Imageco, the corporation eligible for the film tax credit.