Tax Type
Corporation Income Tax
Description
Neighborhood Assistance Act
Topic
Accounting Periods and Methods
Date Issued
12-11-1985
- December 11, 1985
Re: Ruling Request: Neighborhood Assistance Act
Dear ****
This will reply to your letter of September 24, 1985 concerning timing restrictions in the Neighborhood Assistance Act (the "Act").
I agree that Section 63.1-324 of the Code of Virginia specifies the total amount of the tax credit granted for programs approved under the Act in terms of fiscal years of July 1 through June 30.
As you note, Virginia Code Section 63.1-324 limits the tax credit available to a business firm to not more than $175,000 annually. I believe that "annually" refers to the taxable year of the business firm applying for the credit.
The same Section 63.1-324 provides that the credit equals 50% of the total amount invested during the taxable year by the business firm in the approved programs. Again, I believe "taxable year" refers to the taxable year of the business firm.
If you agree with the foregoing interpretations, the only clarifying language needed in Section 63.1-324 is as follows:-
- percent of the total amount invested by the business firm during the its taxable year by the business firm in programs approved pursuant to Section 63.1-323 of this chapter, but no tax credit of less than fifty dollars shall be granted for any individual proposal, nor shall the tax credit exceed $175,000 annually and a business firm may not claim a tax credit in excess of $175,000 per taxable year;
Please let me know if we can be of further assistance.
Sincerely,
W. H. Forst
Tax Commissioner -
Rulings of the Tax Commissioner