The bond purchases would be qualified for investment credit as long as the qualification for the bond program meets CRA (sounds like a slam dunk)

But taking credit for the tax credits you receive...That's not really money spent. You wouldn't take CD credit for the interest earned (obviously it's earned not spent) so I have a very hard time thinking you'll get away with taking credit for the tax credit earnings. An investment must mean out of pocket funds. You're not really using out of pocket funds when we talk about the tax credit piece. That's your yield (though different than interest, still a bonafied yield) and not a cost to you.