A letter ruling
issued by the Tennessee Department of Revenue discusses the enhanced job tax
credit against the corporate income and franchise taxes where the taxpayer has
added headquarters staff jobs. The compensation requirement for each qualified
job created by the taxpayer for purposes of the additional annual job tax
credit was at least 150% of Tennessee's average occupational wage for the month
of January of the year in which the job is created. The taxpayer could claim
the $5,000 “basic” job tax credit in the tax year in which it made the required
capital investment and created a total of 25 qualified jobs, provided that the
investment was made and the jobs were created within 12 months of the effective
date of the business plan. Where the taxpayer met the statutory requirements,
the taxpayer was also allowed to claim the $5,000 additional annual job tax
credit for a period of three years beginning with the first tax year after the
initial job tax credit was created. The “basic” job tax credit could not exceed
50% of the taxpayer's combined Tennessee corporate income and franchise tax
liability shown on the return before any credit is taken. Nevertheless, the
additional annual job tax credit could be used to offset up to 100% of the
taxpayer's Tennessee franchise and excise tax liability for that year.
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