17 February 2010 Internal T.I. 2009-0348461I7 F - Transfert d'une PCMC à une société mère -- summary under Current expense vs. capital acquisition

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 indicated that the CFVPs likely were acquired by Canco on capital account, and were to be included as a Class 10(x) asset.