We did the tax credit work for Carl (thanks for the shoutout man!).
Between 2 CDN entities, only 1 can claim SRED. So if QC Inc did all of its work on behalf of another CDN company, usually the person paying claims the tax credits.
If a US company sub-contracts to you, there's no way the US Co. can claim SRED, so you can. You have to be CDN-controlled to get the biggest tax credit, i.e. the US Co cannot own more than 50% of you. What the CDN Co does with its IP is irrelevant. You can always choose to sell/license your IP to any other company for $1.
If you have any questions, just shoot me an email: rluk[at]flowventures.com