1 | A bill to be entitled |
2 | An act relating to corporate income tax; creating s. |
3 | 220.194, F.S.; establishing credits against the corporate |
4 | income tax for certain taxpayers that operate or provide |
5 | investments for a spaceflight project; providing |
6 | definitions for purposes of the tax credits; establishing |
7 | eligibility requirements for the tax credits; allowing for |
8 | the carryforward of tax credits under certain |
9 | circumstances; providing application and certification |
10 | requirements; requiring the Office of Tourism, Trade, and |
11 | Economic Development to determine the eligibility of |
12 | taxpayers; providing for the expiration and renewal of a |
13 | taxpayer's eligibility for tax credits; providing for |
14 | administration and auditing of tax credits by the |
15 | Department of Revenue; requiring the return and deposit of |
16 | tax credits under certain circumstances; requiring the |
17 | office to consult with Space Florida and adopt rules for |
18 | tax credit applications and certifications; authorizing |
19 | the department to adopt rules for tax administration, |
20 | claims and transfers of tax credits, auditing, and |
21 | reporting; amending s. 14.2015, F.S.; revising the duties |
22 | of the office to include administration of the tax credits |
23 | created by the act; amending s. 220.02, F.S.; revising |
24 | legislative intent relating to the order for applying tax |
25 | credits; providing an effective date. |
26 |
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27 | Be It Enacted by the Legislature of the State of Florida: |
28 |
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29 | Section 1. Section 220.194, Florida Statutes, is created |
30 | to read: |
31 | 220.194 Corporate income tax credits for spaceflight |
32 | projects.-- |
33 | (1) DEFINITIONS.--As used in this section, the term: |
34 | (a) "Eligible costs" means all costs, fees, charges, |
35 | expenses, and amounts incurred by a spaceflight business that |
36 | are related to development of a spaceflight project. |
37 | (b) "Job" means a full-time equivalent position resulting |
38 | directly from a spaceflight project. |
39 | (c) "Launch" means to place or attempt to place a launch |
40 | vehicle or reentry vehicle and any payload from Earth into a |
41 | suborbital trajectory, into Earth orbit in outer space, or |
42 | otherwise into outer space. |
43 | (d) "Launch service" means an activity related to the |
44 | preparation of a launch vehicle and any payload for launch and |
45 | the conduct of a launch. |
46 | (e) "Outer space" means an altitude of at least 50 miles |
47 | above the Earth's surface. |
48 | (f) "Payload" means an object that a spaceflight business |
49 | undertakes to place in outer space by means of a launch vehicle |
50 | or reentry vehicle, including components of the vehicle |
51 | specifically designed or adapted for the object. |
52 | (g) "Reentry" means to return or attempt to return a |
53 | reentry vehicle and any payload from Earth orbit, or from outer |
54 | space, to Earth. |
55 | (h) "Reentry service" means an activity related to the |
56 | preparation of a reentry vehicle and any payload for reentry and |
57 | conduct of the reentry. |
58 | (i) "Spaceflight business" means a business that has its |
59 | principal place of business in the state and that designs or |
60 | manufactures a launch vehicle, reentry vehicle, or components |
61 | thereof; that provides a launch service or reentry service; or |
62 | that provides the payload for a launch vehicle or reentry |
63 | vehicle. |
64 | (j) "Spaceflight project" means an activity performed in a |
65 | spaceport territory by a spaceflight business related to the |
66 | launch or reentry of a launch vehicle or reentry vehicle. The |
67 | term includes a launch service or reentry service. |
68 | (k) "Spaceport territory" has the same meaning as defined |
69 | in s. 331.303. |
70 | (l) "Successful launch" means a launch that successfully |
71 | places a launch vehicle or reentry vehicle and any payload from |
72 | Earth into a suborbital trajectory, into Earth orbit in outer |
73 | space, or otherwise into outer space. |
74 | (m) "Taxpayer" has the same meaning as defined in s. |
75 | 220.03. |
76 | (2) TAX CREDITS.--For tax years beginning on or after |
77 | January 1, 2010: |
78 | (a) A credit against the tax imposed by this chapter in an |
79 | amount equal to the eligible costs, and the ad valorem taxes |
80 | paid in a spaceport territory, shall be granted to a spaceflight |
81 | business that: |
82 | 1. Creates and maintains at least 25 net new jobs in a |
83 | spaceport territory during the previous 3 years; and |
84 | 2. Invests a cumulative total of at least $45 million in |
85 | any spaceflight projects during the previous 3 years. |
86 | (b) A credit against the tax imposed by this chapter shall |
87 | be granted to a spaceflight business eligible for credit under |
88 | paragraph (a) whose spaceflight project resulted in a successful |
89 | launch within the previous 10 years and that incurs net |
90 | operating losses. If credit granted under this paragraph is not |
91 | fully used in any one tax year because of insufficient tax |
92 | liability, the unused amount may be carried forward as provided |
93 | in this paragraph. The amount of the credit is equal to: |
94 | 1. One hundred percent of the net operating losses |
95 | incurred by a spaceflight business during the first year of |
96 | operations in any spaceport territory. The unused amount of the |
97 | credit may be carried forward for up to 10 years. |
98 | 2. One hundred percent of the net operating losses |
99 | incurred by a spaceflight business during its second year of |
100 | operations in any spaceport territory. The unused amount of the |
101 | credit may be carried forward for up to 7 years. |
102 | 3. One hundred percent of the net operating losses |
103 | incurred by a spaceflight business during its third year of |
104 | operations in any spaceport territory. The unused amount of the |
105 | credit may be carried forward for up to 6 years. |
106 | 4. Fifty percent of the net operating losses incurred by a |
107 | spaceflight business during its fourth or subsequent year of |
108 | operations in any spaceport territory. The unused amount of the |
109 | credit may be carried forward for up to 5 years. |
110 | |
111 | A taxpayer or subsequent transferee allowed a tax credit under |
112 | this paragraph may transfer any part of the credit to any |
113 | taxpayer by written agreement. The transferee is entitled to |
114 | apply the credits against the tax with the same effect as if the |
115 | transferee had incurred the net operating losses. |
116 | (c) A credit against the tax imposed by this chapter shall |
117 | be granted to a spaceflight business that creates and maintains |
118 | at least one net new job in a spaceport territory. The amount of |
119 | the credit is equal to 10 percent of the annual wages paid by |
120 | the spaceflight business to each employee in a new job, not to |
121 | exceed $7,500 per employee. Credit for each new job may be |
122 | claimed for 5 years. |
123 | (d) A credit against the tax imposed by this chapter shall |
124 | be granted to a taxpayer that invests a cumulative total of |
125 | machinery and equipment of at least $500,000 in any spaceflight |
126 | projects. The amount of the credit is equal to 7.5 percent of |
127 | the annual investment of machinery and equipment, not to exceed |
128 | 50 percent of the taxpayer's tax liability. If credit granted |
129 | under this paragraph is not fully used in any one tax year |
130 | because of insufficient tax liability, the unused amount may be |
131 | carried forward for up to 5 years. |
132 | (e) Except as provided in paragraph (d), or unless |
133 | transferred as provided in paragraph (b), credits awarded under |
134 | this section may only be granted against the corporate income |
135 | tax liability generated by or arising out of a spaceflight |
136 | project. |
137 | (f) Carryforward credit may be used in a subsequent year |
138 | if the tax imposed by this chapter for that year exceeds the |
139 | credit for which the taxpayer is eligible in that year after |
140 | applying the other credits and unused carryovers in the order |
141 | provided by s. 220.02(8). |
142 | (g) A taxpayer that files a Florida consolidated return as |
143 | a member of an affiliated group under s. 220.131(1) may be |
144 | allowed the credit on a consolidated return basis up to the |
145 | amount of tax imposed upon the consolidated group. |
146 | (h) It is the responsibility of the taxpayer to |
147 | affirmatively demonstrate to the satisfaction of the Department |
148 | of Revenue that the taxpayer is eligible for credit under this |
149 | section. |
150 | (3) APPLICATION AND CERTIFICATION.--To claim credit under |
151 | this section, a taxpayer must submit under oath to the Office of |
152 | Tourism, Trade, and Economic Development an application for tax |
153 | credit that includes the name and address of the taxpayer, the |
154 | total amount of credits sought, and information necessary to |
155 | demonstrate that the taxpayer meets the job creation, |
156 | investment, and other requirements of this section. The director |
157 | of the Office of Tourism, Trade, and Economic Development shall |
158 | determine the taxpayer's eligibility for the credits sought and |
159 | certify the determination to the Department of Revenue. The |
160 | taxpayer must attach the director's certification to the tax |
161 | return on which the credit is claimed. |
162 | (4) SPACEFLIGHT BUSINESS; EXPIRATION OF CREDIT; |
163 | RENEWAL.--Eligibility of a spaceflight business for credit under |
164 | this section shall expire 10 years after the director of the |
165 | Office of Tourism, Trade, and Economic Development certifies |
166 | that the spaceflight business is eligible for credit or 10 years |
167 | after the last successful launch that results from a spaceflight |
168 | project, whichever occurs later. A spaceflight business whose |
169 | eligibility expires under this subsection may renew its |
170 | eligibility upon a successful launch that results from a |
171 | spaceflight project. |
172 | (5) ADMINISTRATION; AUDIT AUTHORITY; RECAPTURE OF |
173 | CREDITS.-- |
174 | (a) In addition to its existing audit and investigative |
175 | authority, the Department of Revenue may perform any additional |
176 | financial and technical audits and investigations, including |
177 | examining the accounts, books, and records of the tax credit |
178 | applicant, that are necessary to verify the eligible costs |
179 | included in the tax credit return and to ensure compliance with |
180 | this section. The Office of Tourism, Trade, and Economic |
181 | Development shall provide technical assistance when requested by |
182 | the Department of Revenue on any technical audits or |
183 | examinations performed under this subsection. |
184 | (b) It is grounds for forfeiture of previously claimed and |
185 | received tax credits if the Department of Revenue determines, as |
186 | a result of either an audit or examination or from information |
187 | received from the Office of Tourism, Trade, and Economic |
188 | Development, that a taxpayer received tax credits under this |
189 | section to which the taxpayer was not entitled. The taxpayer is |
190 | responsible for returning forfeited tax credits to the |
191 | Department of Revenue, and any returned funds shall be deposited |
192 | in the General Revenue Fund. |
193 | (c) The Office of Tourism, Trade, and Economic Development |
194 | may revoke or modify any written decision granting eligibility |
195 | for tax credits under this section if it is discovered that the |
196 | tax credit applicant submitted any false statement, |
197 | representation, or certification in any application, record, |
198 | report, plan, or other document filed in an attempt to receive |
199 | tax credits under this section. The Office of Tourism, Trade, |
200 | and Economic Development shall immediately notify the Department |
201 | of Revenue of any revoked or modified orders affecting |
202 | previously granted tax credits. Additionally, the taxpayer must |
203 | notify the Department of Revenue of any change in its tax credit |
204 | claimed. |
205 | (d) The taxpayer shall file with the Department of Revenue |
206 | an amended return or other report as the department prescribes |
207 | by rule and shall pay any required tax and interest within 60 |
208 | days after the taxpayer receives notification from the Office of |
209 | Tourism, Trade, and Economic Development that previously |
210 | approved tax credits have been revoked or modified. If the |
211 | revocation or modification order is contested, the taxpayer |
212 | shall file an amended return or other report as provided in this |
213 | paragraph within 60 days after a final order is issued following |
214 | proceedings. |
215 | (e) A notice of deficiency may be issued by the Department |
216 | of Revenue at any time within 3 years after the taxpayer |
217 | receives formal notification from the Office of Tourism, Trade, |
218 | and Economic Development that previously approved tax credits |
219 | have been revoked or modified. If a taxpayer fails to notify the |
220 | Department of Revenue of any changes to its tax credit claimed, |
221 | a notice of deficiency may be issued at any time. |
222 | (6) RULES.-- |
223 | (a) The Office of Tourism, Trade, and Economic |
224 | Development, in consultation with Space Florida, shall adopt |
225 | rules under ss. 120.536(1) and 120.54 to administer this |
226 | section, including rules relating to the forms for certification |
227 | of a taxpayer's eligibility to claim a tax credit under this |
228 | section and the application and certification procedures, |
229 | guidelines, and requirements necessary to administer this |
230 | section. |
231 | (b) The Department of Revenue may adopt rules under ss. |
232 | 120.536(1) and 120.54 to administer this section, including |
233 | rules relating to: |
234 | 1. The forms required to claim a tax credit under this |
235 | section, the requirements and basis for establishing an |
236 | entitlement to a credit, and the examination and audit |
237 | procedures required to administer this section. |
238 | 2. The implementation and administration of the provisions |
239 | allowing a transfer of a tax credit, including rules prescribing |
240 | forms, reporting requirements, and specific procedures, |
241 | guidelines, and requirements necessary to transfer a tax credit. |
242 | Section 2. Paragraph (f) of subsection (2) of section |
243 | 14.2015, Florida Statutes, is amended to read: |
244 | 14.2015 Office of Tourism, Trade, and Economic |
245 | Development; creation; powers and duties.-- |
246 | (2) The purpose of the Office of Tourism, Trade, and |
247 | Economic Development is to assist the Governor in working with |
248 | the Legislature, state agencies, business leaders, and economic |
249 | development professionals to formulate and implement coherent |
250 | and consistent policies and strategies designed to provide |
251 | economic opportunities for all Floridians. To accomplish such |
252 | purposes, the Office of Tourism, Trade, and Economic Development |
253 | shall: |
254 | (f)1. Administer the Florida Enterprise Zone Act under ss. |
255 | 290.001-290.016, the community contribution tax credit program |
256 | under ss. 220.183 and 624.5105, the tax refund program for |
257 | qualified target industry businesses under s. 288.106, the tax- |
258 | refund program for qualified defense contractors and space |
259 | flight business contractors under s. 288.1045, contracts for |
260 | transportation projects under s. 288.063, the sports franchise |
261 | facility program under s. 288.1162, the professional golf hall |
262 | of fame facility program under s. 288.1168, the expedited |
263 | permitting process under s. 403.973, the Rural Community |
264 | Development Revolving Loan Fund under s. 288.065, the Regional |
265 | Rural Development Grants Program under s. 288.018, the Certified |
266 | Capital Company Act under s. 288.99, the Florida State Rural |
267 | Development Council, the Rural Economic Development Initiative, |
268 | the corporate income tax credits for spaceflight projects under |
269 | s. 220.194, and other programs that are specifically assigned to |
270 | the office by law, by the appropriations process, or by the |
271 | Governor. Notwithstanding any other provisions of law, the |
272 | office may expend interest earned from the investment of program |
273 | funds deposited in the Grants and Donations Trust Fund to |
274 | contract for the administration of the programs, or portions of |
275 | the programs, enumerated in this paragraph or assigned to the |
276 | office by law, by the appropriations process, or by the |
277 | Governor. Such expenditures shall be subject to review under |
278 | chapter 216. |
279 | 2. The office may enter into contracts in connection with |
280 | the fulfillment of its duties concerning the Florida First |
281 | Business Bond Pool under chapter 159, tax incentives under |
282 | chapters 212 and 220, tax incentives under the Certified Capital |
283 | Company Act in chapter 288, foreign offices under chapter 288, |
284 | the Enterprise Zone program under chapter 290, the Seaport |
285 | Employment Training program under chapter 311, the Florida |
286 | Professional Sports Team License Plates under chapter 320, |
287 | Spaceport Florida under chapter 331, Expedited Permitting under |
288 | chapter 403, and in carrying out other functions that are |
289 | specifically assigned to the office by law, by the |
290 | appropriations process, or by the Governor. |
291 | Section 3. Subsection (8) of section 220.02, Florida |
292 | Statutes, is amended to read: |
293 | 220.02 Legislative intent.-- |
294 | (8) It is the intent of the Legislature that credits |
295 | against either the corporate income tax or the franchise tax be |
296 | applied in the following order: those enumerated in s. 631.828, |
297 | those enumerated in s. 220.191, those enumerated in s. 220.181, |
298 | those enumerated in s. 220.183, those enumerated in s. 220.182, |
299 | those enumerated in s. 220.1895, those enumerated in s. 221.02, |
300 | those enumerated in s. 220.184, those enumerated in s. 220.186, |
301 | those enumerated in s. 220.1845, those enumerated in s. 220.19, |
302 | those enumerated in s. 220.185, those enumerated in s. 220.187, |
303 | those enumerated in s. 220.192, and those enumerated in s. |
304 | 220.193, and those enumerated in s. 220.194. |
305 | Section 4. This act shall take effect July 1, 2009. |