CRA indicates that the covered worker requirements extend to their installation of a concrete foundation to support substantial CCUS equipment

In order to support a substantial piece of equipment described in Class 57(a) in respect of a carbon capture utilization and storage (CCUS) project, Canco will construct a concrete foundation, including the excavation of a hole, the installation of pilings, and the pouring of concrete. The CRA found that this foundation would qualify under Class 57(f) as a structure, substantially all of which was used in the installation of Class 57(a) equipment, so that the foundation would itself be a specified property as defined in s. 127.46(1).

Accordingly, if Canco had elected to meet the labour requirements under s. 127.46(2) (e.g., meeting prevailing union rates) so as not to have the maximum ITC rates reduced, those labour requirements would extend to the above installation work for the foundation.

Neal Armstrong. Summary of 25 February 2026 External T.I. 2025-1081921E5 under Class 57(f) and s. 127.46(1) – covered worker – (a).