21 October 2024 External T.I. 2024-1027501E5 - Stacking of investment tax credits and CCA -- summary under Element A

The $10,000,000 capital cost of the Property will be included in the UCC of Class 43.2, based on its date of acquisition. The Property meets the definition of accelerated investment incentive property (“AIIP”) in Reg. 1104(4) (i.e., it is depreciable property that is (i) new, (ii) acquired after November 20, 2018 and (iii) became available for use before 2028), so that the taxpayer may deduct up to $7,500,000 of CCA for 2024, computed as a grossed-up (by 50%) capital cost of $15,000,000 multiplied by the 50% Class 43.2 CCA deduction.