Many states have created tax credits to attract movie and television productions to their states. The most powerful incentives over the last decade have been state income tax credits.
California eliminated the California Enterprise Zone Tax Credit program and replaced it with a more limited hiring credit.
The emergence of online marketplaces and auction houses has provided a single point of contact for both sellers and buyers, making sales and purchases of transferable state tax credits more common.
The IRS has not issued published guidance on corporations’ tax treatment of refundable state and local tax credits. However, the Office of Chief Counsel, through a recent legal memorandum and other informal nonprecedential advisories, has provided insight as to the treatment of these credits.
Practitioners with clients conducting qualified research could find some hidden gems among state research credits