Fi30. Is the vintage year of an infrastructure credit the year in which the investment expenditure certificate is approved?
Because the infrastructure credit may be carried forward to offset MBT tax liability for a specified period of years or until used up, whichever is less, the Department presumes that the use of the term "vintage year" in the question is intended to mean the year in which the tax credit may first be used to offset tax liability and when the period of time the carryforward of the credit amount begins. To that end, the infrastructure credit must be claimed in the tax year in which the investment expenditure certificate is issued (i.e. approved) by the Michigan Film Office. The tax year in which the certificate is issued would be the "vintage year." The portion of the credit that exceeds the tax liability of the taxpayer for the tax year may be carried forward to offset MBT tax liability in subsequent tax years subsequent to the "vintage year" for a period not to exceed 10 years or until used up, which occurs first. MCL 208.1455(7).