Florida Senate - 2023 CS for SB 288
By the Committee on Finance and Tax; and Senators DiCeglie,
Rodriguez, and Stewart
593-02553-23 2023288c1
1 A bill to be entitled
2 An act relating to the Florida Main Street Program and
3 historic preservation tax credits; creating s.
4 220.197, F.S.; providing a short title; defining
5 terms; providing a credit against the state corporate
6 income tax and the insurance premium tax for qualified
7 expenses in rehabilitating certain historic
8 structures; specifying eligibility requirements for
9 the tax credit; specifying requirements for taxpayers
10 claiming or transferring tax credits; specifying
11 requirements for the Division of Historical Resources
12 of the Department of State for evaluating and
13 certifying applications for tax credits; specifying
14 the allowable amounts of tax credits; providing
15 construction; authorizing the carryforward, sale, and
16 transfer of tax credits subject to certain
17 requirements and limitations; providing the Department
18 of Revenue and the division audit and examination
19 powers for specified purposes; requiring the return of
20 forfeited tax credits under certain circumstances;
21 providing penalties; requiring the Department of
22 Revenue to provide specified annual reports to the
23 Legislature; providing duties of the Department of
24 Revenue; authorizing the Department of Revenue and the
25 division to adopt rules; amending s. 213.053, F.S.;
26 authorizing the Department of Revenue to make certain
27 information available to the division and the Federal
28 Government for a specified purpose; amending s.
29 220.02, F.S.; specifying the order in which the credit
30 is applied against the corporate income tax or
31 franchise tax; amending s. 220.13, F.S.; requiring the
32 addition of amounts taken for the credit to taxable
33 income; amending s. 624.509, F.S.; specifying the
34 order in which the credit is applied against the
35 insurance premium tax; authorizing the Department of
36 Revenue to adopt emergency rules; providing for
37 expiration of that authority; providing applicability;
38 providing effective dates.
39
40 WHEREAS, historic revitalization creates highly paid local
41 construction jobs, and
42 WHEREAS, historic rehabilitation increases the value of
43 buildings and results in a growing state and local tax base, and
44 WHEREAS, historic revitalization boosts heritage tourism
45 and creates thriving downtowns that are attractive to main
46 street businesses, and
47 WHEREAS, reusing historic buildings creates affordable
48 spaces for small business incubation, and
49 WHEREAS, repurposing historic buildings saves resources and
50 activates vacant spaces, and
51 WHEREAS, historic rehabilitation projects leverage
52 significant private investment, and
53 WHEREAS, leveraging state tax incentives increases the
54 effectiveness of federal Historic Preservation Tax Incentives
55 and the Opportunity Zones Program to encourage the historic
56 preservation of existing buildings, and
57 WHEREAS, an increase in rehabilitation activity occurs when
58 a state incentive is combined with federal Historic Preservation
59 Tax Incentives, and
60 WHEREAS, many historic buildings in this state need safety
61 upgrades and other improvements that require both public and
62 private investment to return these buildings as assets of their
63 local communities, NOW, THEREFORE,
64
65 Be It Enacted by the Legislature of the State of Florida:
66
67 Section 1. Section 220.197, Florida Statutes, is created to
68 read:
69 220.197 Main Street Historic Tourism and Revitalization
70 Act; tax credits; reports.—
71 (1) SHORT TITLE.—This act may be cited as the “Main Street
72 Historic Tourism and Revitalization Act.”
73 (2) DEFINITIONS.—As used in this section, the term:
74 (a) “Accredited Main Street Program” means an active
75 Florida Main Street Program or the Orlando Main Streets program,
76 provided that such program meets the Main Street America
77 accreditation standards. An Accredited Main Street Program must
78 meet all of the following criteria:
79 1. Have broad-based community support for the commercial
80 district revitalization process with strong support from the
81 public and private sectors.
82 2. Have a developed vision and mission statement relevant
83 to community conditions and to Main Street America’s
84 organizational stage.
85 3. Have a comprehensive Main Street America work plan.
86 4. Possess a historic preservation ethic.
87 5. Have an active board of directors and committees.
88 6. Have an adequate operating budget.
89 7. Have a paid professional program manager.
90 8. Conduct a program of ongoing training for staff and
91 volunteers.
92 9. Report key statistics.
93 10. Be a current member of Main Street America.
94 (b) “Certified historic structure” means a building and its
95 structural components as defined in 36 C.F.R. s. 67.2 which is
96 of a character subject to the allowance for depreciation
97 provided in s. 167 of the Internal Revenue Code of 1986, as
98 amended, and which is:
99 1. Individually listed in the National Register of Historic
100 Places; or
101 2. Located within a registered historic district and
102 certified by the United States Secretary of the Interior as
103 being of historic significance to the registered historic
104 district as set forth in 36 C.F.R. s. 67.2.
105 (c) “Certified rehabilitation” means the rehabilitation of
106 a certified historic structure which the United States Secretary
107 of the Interior has certified to the United States Secretary of
108 the Treasury as being consistent with the historic character of
109 the certified historic structure and, if applicable, consistent
110 with the registered historic district in which the certified
111 historic structure is located as set forth in 36 C.F.R. s. 67.2.
112 (d) “Division” means the Division of Historical Resources
113 of the Department of State.
114 (e) “Florida Main Street Program” means a statewide
115 historic preservation-based downtown revitalization assistance
116 program created, maintained, and administered by the division
117 under s. 267.031(5).
118 (f) “Local program area” means the specific geographic area
119 in which an Accredited Main Street Program is conducted as
120 approved and maintained by the division or in which the Orlando
121 Main Streets program is conducted.
122 (g) “Long-term leasehold” means a leasehold in a
123 nonresidential real property for a term of 39 years or more or a
124 leasehold in a residential real property for a term of 27.5
125 years or more.
126 (h) “Main Street America” means a national network of
127 grassroots organizations revitalizing historic downtown areas
128 under the leadership of the National Main Street Center, Inc., a
129 subsidiary of the National Trust for Historic Preservation.
130 (i) “National Register of Historic Places” means the list
131 of historic properties significant in American history,
132 architecture, archeology, engineering, and culture maintained by
133 the United States Secretary of the Interior as authorized in 54
134 U.S.C. s. 3021.
135 (j) “Orlando Main Streets” means a historic preservation
136 based district revitalization program administered by the City
137 of Orlando.
138 (k) “Placed in service” means the time that property is
139 first placed by the taxpayer in a condition or state of
140 readiness and availability for a specifically assigned function,
141 whether for use in a trade or business, for the production of
142 income, or in a tax-exempt activity.
143 (l) “Qualified expenses” means rehabilitation expenditures
144 incurred in this state which qualify for the credit under 26
145 U.S.C. s. 47.
146 (m) “Registered historic district” means a district listed
147 in the National Register of Historic Places or a district:
148 1. Designated under general law or local ordinance and
149 certified by the United States Secretary of the Interior as
150 meeting criteria that will substantially achieve the purposes of
151 preserving and rehabilitating buildings of historic significance
152 to the district; and
153 2. Certified by the United States Secretary of the Interior
154 as meeting substantially all of the requirements for listing a
155 district in the National Register of Historic Places.
156 (n) “Taxpayer” has the same meaning as in s. 220.03(1)(z),
157 but also includes an insurer subject to the insurance premium
158 tax under s. 624.509.
159 (3) ELIGIBILITY.—
160 (a) To receive a tax credit under this section, an
161 applicant must apply to the division, no later than 6 months
162 after the date the certified historic structure is placed in
163 service, for a tax credit for qualified expenses in the amount
164 and under the conditions and limitations provided in this
165 section. The applicant must provide the division with all of the
166 following:
167 1. Documentation showing that:
168 a. The rehabilitation is a certified rehabilitation;
169 b. The structure is a certified historic structure, is
170 income-producing, is located within this state, and is placed
171 into service on or after January 1, 2024;
172 c. The applicant had an ownership or a long-term leasehold
173 interest in the certified historic structure in the year during
174 which the certified historic structure was placed into service;
175 d. The total amount of qualified expenses incurred in
176 rehabilitating the certified historic structure exceeded $5,000;
177 e. The qualified expenses were incurred in this state; and
178 f. The applicant received a tax credit for the qualified
179 expenses under 26 U.S.C. s. 47.
180 2. An official certificate of eligibility from the
181 division, signed by the State Historic Preservation Officer or
182 the Deputy State Historic Preservation Officer, attesting that
183 the project has been approved by the National Park Service. The
184 attestation must identify if the project is located within a
185 local program area.
186 3. National Park Service Form 10-168c (Rev. 2019), titled
187 “Historic Preservation Certification Application-Part 3-Request
188 for Certification of Completed Work,” or a similar form, signed
189 by an officer of the National Park Service, attesting that the
190 completed rehabilitation meets the United States Secretary of
191 the Interior’s Standards for Rehabilitation and is consistent
192 with the historic character of the property and, if applicable,
193 the district in which the completed rehabilitation is located.
194 The form may be obtained from the National Park Service.
195 4. The dates during which the certified historic structure
196 was rehabilitated, the date the certified historic structure was
197 placed into service after the certified rehabilitation was
198 completed, and evidence that the certified historic structure
199 was placed into service after the certified rehabilitation was
200 completed.
201 5. A list of total qualified expenses incurred in
202 rehabilitating the certified historic structure. For certified
203 rehabilitations with qualified expenses that exceed $750,000,
204 the applicant must submit an audited cost report issued by a
205 certified public accountant which itemizes the qualified
206 expenses incurred in rehabilitating the certified historic
207 structure. An applicant may submit an audited cost report issued
208 by a certified public accountant which was created for purposes
209 of applying for a federal historic rehabilitation tax credit and
210 which includes all of the qualified expenses incurred in
211 rehabilitating the certified historic structure.
212 6. An attestation of the total qualified expenses incurred
213 by the applicant in rehabilitating the certified historic
214 structure.
215 7. The information required to be reported by the
216 department in subsection (8) to enable the department to compile
217 its annual report.
218
219 This paragraph may not be construed to restrict an applicant
220 from making an application with the division before the
221 certified historic structure is placed in service. However, a
222 final determination on eligibility may not be made until the
223 certified historic structure is placed in service.
224 (b) Within 90 days after receipt of the information
225 required under paragraph (a) or the certified historic structure
226 is placed in service, whichever is later, the division shall
227 approve or deny the application. If approved, the division must
228 provide a letter of certification to the applicant consistent
229 with any restrictions imposed. If the division denies any part
230 of the requested credit, the division must inform the applicant
231 of the grounds for the denial. The division must submit a copy
232 of the certification and the information provided by the
233 applicant to the department within 10 days after the division’s
234 approval.
235 (4) CERTIFIED REHABILITATION TAX CREDIT.—For taxable years
236 beginning on or after January 1, 2024, there is allowed a credit
237 against any tax due for a taxable year under this chapter after
238 the application of any other allowable credits by the taxpayer
239 in an amount equal to:
240 (a) Twenty percent of the total qualified expenses incurred
241 in this state in rehabilitating a certified historic structure
242 that has been approved by the National Park Service to receive
243 the federal historic rehabilitation tax credit; or
244 (b) Thirty percent of the total qualified expenses incurred
245 in this state in rehabilitating a certified historic structure
246 that has been approved by the National Park Service to receive
247 the federal historic rehabilitation tax credit and that is
248 located within a local program area.
249
250 The tax credit may be used to offset the corporate income tax
251 imposed under this chapter and the insurance premium tax imposed
252 in s. 624.509. An insurer claiming a credit against insurance
253 premium tax liability under this section may not be required to
254 pay any additional retaliatory tax levied pursuant to s.
255 624.5091 as a result of claiming such credit. Section 624.5091
256 does not limit such credit in any manner.
257 (5) CARRYFORWARD OF TAX CREDIT.—
258 (a) If a tax credit exceeds the amount of tax owed, the
259 taxpayer may carry forward the unused tax credit for a period of
260 up to 5 taxable years.
261 (b) A carryforward is considered the remaining portion of a
262 tax credit that cannot be claimed in the current taxable year.
263 (6) SALE OR TRANSFER OF TAX CREDIT.—
264 (a) All or part of the tax credit may be sold or
265 transferred.
266 (b) A taxpayer to which all or part of the tax credit is
267 sold or transferred may sell or transfer to another taxpayer all
268 or part of the tax credit that may otherwise be claimed.
269 (c) A taxpayer that sells or transfers a tax credit to
270 another taxpayer must provide a copy of the certificate of
271 eligibility provided under subparagraph (3)(a)2. together with
272 the audited cost report, if applicable, to the purchaser or
273 transferee.
274 (d) Qualified expenses may be counted only once in
275 determining the amount of an available tax credit, and more than
276 one taxpayer may not claim a tax credit for the same qualified
277 expenses.
278 (e) There is no limit on the total number of transactions
279 for the sale or transfer of all or part of a tax credit.
280 (f)1. No later than the 30th day after the date of a sale
281 or transfer, the seller or transferor and the purchaser or
282 transferee shall jointly submit written notice of the sale or
283 transfer to the department on a form prescribed by the
284 department. The notice must include all of the following:
285 a. The date of the sale or transfer.
286 b. The amount of the tax credit sold or transferred.
287 c. The name and federal tax identification number of the
288 seller or transferor of the tax credit and the purchaser or
289 transferee.
290 d. The amount of the tax credit owned by the seller or
291 transferor before the sale or transfer and the amount the seller
292 or transferor retained, if any, after the sale or transfer.
293 2. The sale or transfer of a tax credit under this
294 subsection does not extend the period for which a tax credit may
295 be carried forward and does not increase the total amount of the
296 tax credit that may be claimed.
297 3. If a taxpayer claims a tax credit for qualified
298 expenses, another taxpayer may not use the same expenses as the
299 basis for claiming a tax credit.
300 4. Notwithstanding the requirements of this subsection, a
301 tax credit earned by, purchased by, or transferred to a
302 partnership, limited liability company, S corporation, or other
303 pass-through taxpayer may be allocated to the partners, members,
304 or shareholders of that taxpayer in accordance with any
305 agreement among the partners, members, or shareholders and
306 without regard to the ownership interest of the partners,
307 members, or shareholders in the rehabilitated certified historic
308 structure.
309 (g) If the tax credit is reduced due to a determination,
310 examination, or audit by the department, the tax deficiency
311 shall be recovered from the taxpayer that sold or transferred
312 the tax credit or the purchaser or transferee that claimed the
313 tax credit up to the amount of the tax credit taken.
314 (h) Any subsequent deficiencies shall be assessed against
315 the purchaser or transferee that claimed the tax credit or, in
316 the case of multiple succeeding entities, in the order of tax
317 credit succession.
318 (7) AUDIT AUTHORITY; REVOCATION AND FORFEITURE OF TAX
319 CREDITS; FRAUDULENT CLAIMS.—
320 (a) The department, with assistance from the division, may
321 perform any additional financial and technical audits and
322 examinations, including examining the accounts, books, or
323 records of the tax credit applicant, to verify the legitimacy of
324 the qualified expenses included in a tax credit return and to
325 ensure compliance with this section. If requested by the
326 department, the division must provide technical assistance for
327 any technical audits or examinations performed under this
328 subsection.
329 (b) It is grounds for forfeiture of previously claimed and
330 received tax credits if the department determines, as a result
331 of an audit or information received from the division or the
332 United States Department of the Interior, that an applicant or a
333 taxpayer received a tax credit pursuant to this section to which
334 the taxpayer was not entitled. In the case of fraud, the
335 taxpayer may not claim any future tax credits under this
336 section.
337 (c) The taxpayer must return forfeited tax credits to the
338 department, and such funds shall be paid into the General
339 Revenue Fund.
340 (d) The taxpayer shall file with the department an amended
341 tax return or such other report as the department prescribes and
342 shall pay any required tax within 60 days after the taxpayer
343 receives notification from the United States Internal Revenue
344 Service that a previously approved tax credit has been revoked
345 or modified, if uncontested, or within 60 days after a final
346 order is issued following proceedings involving a contested
347 revocation or modification order.
348 (e) A notice of deficiency may be issued by the department
349 at any time within 5 years after the date on which the taxpayer
350 receives notification from the United States Internal Revenue
351 Service that a previously approved tax credit has been revoked
352 or modified. If a taxpayer fails to notify the department of any
353 change in its tax credit claimed, a notice of deficiency may be
354 issued at any time. In either case, the amount of any proposed
355 assessment set forth in such notice of deficiency is limited to
356 the amount of the tax credit claimed.
357 (f) A taxpayer that fails to report and timely pay any tax
358 due as a result of the forfeiture of its tax credit violates
359 this section and is subject to applicable penalties and
360 interest.
361 (8) ANNUAL REPORT.—Based on the applications submitted and
362 approved, the department shall submit a report by December 1 of
363 each year to the President of the Senate and the Speaker of the
364 House of Representatives which identifies, in the aggregate, all
365 of the following:
366 (a) The number of employees hired during construction
367 phases.
368 (b) The use of each newly rehabilitated building and the
369 expected number of employees hired.
370 (c) The number of affordable housing units created or
371 preserved. As used in this paragraph, the term “affordable” has
372 the same meaning as in s. 420.0004.
373 (d) The property values before and after the certified
374 rehabilitations.
375 (9) DEPARTMENT DUTIES.—The department shall:
376 (a) Establish a cooperative agreement with the division.
377 (b) Adopt any necessary forms required to claim a tax
378 credit under this section.
379 (c) Provide administrative guidelines and procedures
380 required to administer this section, including rules
381 establishing an entitlement to and sale or transfer of a tax
382 credit under this section.
383 (d) Provide examination and audit procedures required to
384 administer this section.
385 (10) RULES.—The department and the division may adopt rules
386 to administer this section.
387 Section 2. Subsection (24) is added to section 213.053,
388 Florida Statutes, to read:
389 213.053 Confidentiality and information sharing.—
390 (24) The department may make available to the Division of
391 Historical Resources of the Department of State and the
392 Secretary of the United States Department of the Interior or his
393 or her delegate, exclusively for official purposes, information
394 for the purposes of administering the Main Street Historic
395 Tourism and Revitalization Act pursuant to s. 220.197.
396 Section 3. Subsection (8) of section 220.02, Florida
397 Statutes, is amended to read:
398 220.02 Legislative intent.—
399 (8) It is the intent of the Legislature that credits
400 against either the corporate income tax or the franchise tax be
401 applied in the following order: those enumerated in s. 631.828,
402 those enumerated in s. 220.191, those enumerated in s. 220.181,
403 those enumerated in s. 220.183, those enumerated in s. 220.182,
404 those enumerated in s. 220.1895, those enumerated in s. 220.195,
405 those enumerated in s. 220.184, those enumerated in s. 220.186,
406 those enumerated in s. 220.1845, those enumerated in s. 220.19,
407 those enumerated in s. 220.185, those enumerated in s. 220.1875,
408 those enumerated in s. 220.1876, those enumerated in s.
409 220.1877, those enumerated in s. 220.193, those enumerated in s.
410 288.9916, those enumerated in s. 220.1899, those enumerated in
411 s. 220.194, those enumerated in s. 220.196, those enumerated in
412 s. 220.198, and those enumerated in s. 220.1915, and those
413 enumerated in s. 220.197.
414 Section 4. Paragraph (a) of subsection (1) of section
415 220.13, Florida Statutes, is amended to read:
416 220.13 “Adjusted federal income” defined.—
417 (1) The term “adjusted federal income” means an amount
418 equal to the taxpayer’s taxable income as defined in subsection
419 (2), or such taxable income of more than one taxpayer as
420 provided in s. 220.131, for the taxable year, adjusted as
421 follows:
422 (a) Additions.—There shall be added to such taxable income:
423 1.a. The amount of any tax upon or measured by income,
424 excluding taxes based on gross receipts or revenues, paid or
425 accrued as a liability to the District of Columbia or any state
426 of the United States which is deductible from gross income in
427 the computation of taxable income for the taxable year.
428 b. Notwithstanding sub-subparagraph a., if a credit taken
429 under s. 220.1875, s. 220.1876, or s. 220.1877 is added to
430 taxable income in a previous taxable year under subparagraph 11.
431 and is taken as a deduction for federal tax purposes in the
432 current taxable year, the amount of the deduction allowed shall
433 not be added to taxable income in the current year. The
434 exception in this sub-subparagraph is intended to ensure that
435 the credit under s. 220.1875, s. 220.1876, or s. 220.1877 is
436 added in the applicable taxable year and does not result in a
437 duplicate addition in a subsequent year.
438 2. The amount of interest which is excluded from taxable
439 income under s. 103(a) of the Internal Revenue Code or any other
440 federal law, less the associated expenses disallowed in the
441 computation of taxable income under s. 265 of the Internal
442 Revenue Code or any other law, excluding 60 percent of any
443 amounts included in alternative minimum taxable income, as
444 defined in s. 55(b)(2) of the Internal Revenue Code, if the
445 taxpayer pays tax under s. 220.11(3).
446 3. In the case of a regulated investment company or real
447 estate investment trust, an amount equal to the excess of the
448 net long-term capital gain for the taxable year over the amount
449 of the capital gain dividends attributable to the taxable year.
450 4. That portion of the wages or salaries paid or incurred
451 for the taxable year which is equal to the amount of the credit
452 allowable for the taxable year under s. 220.181. This
453 subparagraph shall expire on the date specified in s. 290.016
454 for the expiration of the Florida Enterprise Zone Act.
455 5. That portion of the ad valorem school taxes paid or
456 incurred for the taxable year which is equal to the amount of
457 the credit allowable for the taxable year under s. 220.182. This
458 subparagraph shall expire on the date specified in s. 290.016
459 for the expiration of the Florida Enterprise Zone Act.
460 6. The amount taken as a credit under s. 220.195 which is
461 deductible from gross income in the computation of taxable
462 income for the taxable year.
463 7. That portion of assessments to fund a guaranty
464 association incurred for the taxable year which is equal to the
465 amount of the credit allowable for the taxable year.
466 8. In the case of a nonprofit corporation which holds a
467 pari-mutuel permit and which is exempt from federal income tax
468 as a farmers’ cooperative, an amount equal to the excess of the
469 gross income attributable to the pari-mutuel operations over the
470 attributable expenses for the taxable year.
471 9. The amount taken as a credit for the taxable year under
472 s. 220.1895.
473 10. Up to nine percent of the eligible basis of any
474 designated project which is equal to the credit allowable for
475 the taxable year under s. 220.185.
476 11. Any amount taken as a credit for the taxable year under
477 s. 220.1875, s. 220.1876, or s. 220.1877. The addition in this
478 subparagraph is intended to ensure that the same amount is not
479 allowed for the tax purposes of this state as both a deduction
480 from income and a credit against the tax. This addition is not
481 intended to result in adding the same expense back to income
482 more than once.
483 12. The amount taken as a credit for the taxable year under
484 s. 220.193.
485 13. Any portion of a qualified investment, as defined in s.
486 288.9913, which is claimed as a deduction by the taxpayer and
487 taken as a credit against income tax pursuant to s. 288.9916.
488 14. The costs to acquire a tax credit pursuant to s.
489 288.1254(5) that are deducted from or otherwise reduce federal
490 taxable income for the taxable year.
491 15. The amount taken as a credit for the taxable year
492 pursuant to s. 220.194.
493 16. The amount taken as a credit for the taxable year under
494 s. 220.196. The addition in this subparagraph is intended to
495 ensure that the same amount is not allowed for the tax purposes
496 of this state as both a deduction from income and a credit
497 against the tax. The addition is not intended to result in
498 adding the same expense back to income more than once.
499 17. The amount taken as a credit for the taxable year
500 pursuant to s. 220.198.
501 18. The amount taken as a credit for the taxable year
502 pursuant to s. 220.1915.
503 19. The amount taken as a credit for the taxable year
504 pursuant to s. 220.197.
505 Section 5. Subsection (7) of section 624.509, Florida
506 Statutes, is amended to read:
507 624.509 Premium tax; rate and computation.—
508 (7) Credits and deductions against the tax imposed by this
509 section shall be taken in the following order: deductions for
510 assessments made pursuant to s. 440.51; credits for taxes paid
511 under ss. 175.101 and 185.08; credits for income taxes paid
512 under chapter 220 and the credit allowed under subsection (5),
513 as these credits are limited by subsection (6); the credit
514 allowed under s. 624.51057; the credit allowed under s. 220.197;
515 and all other available credits and deductions.
516 Section 6. (1) The Department of Revenue may, and all
517 conditions are deemed met to, adopt emergency rules under s.
518 120.54(4), Florida Statutes, for the purpose of implementing the
519 Main Street Historic Tourism and Revitalization Act.
520 (2) Notwithstanding any other law, emergency rules adopted
521 under this section are effective for 6 months after adoption and
522 may be renewed during the pendency of procedures to adopt
523 permanent rules addressing the subject of the emergency rules.
524 (3) This section shall take effect upon this act becoming a
525 law and expires July 1, 2024.
526 Section 7. This act applies to taxable years beginning, and
527 for qualified expenses incurred, on or after January 1, 2024.
528 Section 8. Except as otherwise expressly provided in this
529 act and except for this section, which shall take effect upon
530 this act becoming a law, this act shall take effect January 1,
531 2024.