Regarding whether the Quebec capital tax credit should be recognized at the end of a taxation year notwithstanding that it has not yet been received, CRA stated:
According to the jurisprudence, an amount is receivable when a taxpayer has an absolute entitlement to receive it, even though it is not necessarily due. In order to be "entitled to receive" an amount, it must be shown that the conditions on which the claim is based are satisfied. According to our understanding of the credit in section 1135.1 of the QTA, a taxpayer is entitled to receive the amount of the credit, not exceeding the capital tax otherwise payable for the year, at the end of its taxation year. However, the taxpayer will not be entitled to receive the portion of the credit that is carried forward to a subsequent taxation year.