19 January 2011 External T.I. 2010-0390831E5 - Compute LRIP - corporation becomes non-CCPC -- summary under Subsection 89(8)

A future income tax asset is not "property" within the meaning of variable A of s. 89(8) as it does not represent a "right" - unless the corporation has a right to receive a refund of the tax. Likewise, future income tax liabilities are not included in variable D if the corporation has no obligation to pay such amounts.