Compliance Submission
The Department of Community and Economic Development monitoring and compliance team seeks to ensure comprehensive oversight of the entire life cycle of a project.

Compliance Submission

A key component of successful development requires effective oversight and monitoring of City investments. Please visit the links below to find reporting documents.

Commercial Reinvestment Area (CRA) Compliance

Commercial CRA Completion Application

Use the following link to download the CRA Project Completion Application. This PDF form and its required supplemental documentation should be submitted when you have been issued a Certificate of Occupancy (and LEED certificate, if applicable) and you can provide an accepted form of cost documentation. If the Completion Application is in compliance with the CRA Agreement, the City informs the Hamilton County Auditor to put the abatement into effect. Once put into effect, the abatement term corresponds to when the first partial assessment related to the improvements was/is completed. Please contact Carmen Gulliford at carmen.gulliford@cincinnati-oh.gov or 513-352-4545 if you have further questions.

CRA Annual Status Report

To access your company’s 2017 CRA Annual Report, enter your City Contract Number (found on your request email) in the entry box below. The report form will appear and you will need to review the information from your agreement and report on jobs, payroll, and investment for your project as of December 31, 2017. At the end, provide your name to record who filled out the report and then click “Submit”.
 
If you have any questions, please contact Carmen Gulliford at carmen.gulliford@cincinnati-oh.gov or 513-352-4545; OR, Michael Banish at michael.banish@cincinnati-oh.gov or 513-352-1958.

CRA Annual Reports are due March 16, 2018. The City is required to report to the State of Ohio Development Services Agency by March 31.

CRA Annual Reports are due March 16, 2018.

 

Job Creation Tax Credit (JCTC) Compliance

Tax Year 2017 JCTC/PIR Annual Report forms are online below and are due May 4, 2018.

Job Creation Tax Credit and Property Investment Reimbursement Agreements require annual progress reports to the City. These annual reports need to be submitted in three parts: the Employee Listing spreadsheet, the Calculations spreadsheet, and the Annual Progress Report form. Each of these forms is listed below with additional instructions. When you have submitted the forms and the City has verified your compliance status and determined your tax credit eligibility, you will receive a verification letter that you can use to document your tax credit on your City Business Tax Return (see STEP SIX below).

STEP ONE: Click here for the Employee Listing spreadsheet template. This Excel template requires full Social Security numbers, start and termination dates, amounts paid in 2017, and taxes withheld in 2017 for each employee. The spreadsheet template can be filled in, or, most likely, the Company uses a payroll application or third party payroll management company that can produce the spreadsheet. Save this spreadsheet on your computer with a relevant filename, e.g., “2017 JCTC Employee Listing.xlsx.”

STEP TWO: Click here for the Calculations spreadsheet template. This spreadsheet includes baseline jobs, monthly head counts, the “Net Number of New Employees” calculation, and your tax credit calculation. The tabs must be completed in order, as each one uses data from the previous one to run its formulas. SPECIAL NOTE: There are two “Net Number of New Employees” spreadsheets. One calculates Net Number of New Employees using a 3-month average, and one uses a 12-month average. Please complete both spreadsheets to calculate your Net Number of New Employees. The City will use the calculations in determining your compliance and the amount of your tax credit, if any. 

You do not need to complete the last tab/worksheet if your Incentive Term has expired and you are in the Employment Retention Period. (If you are not sure, please complete the last worksheet as part of your submission and City staff will determine if it is needed.

Save this spreadsheet on your computer with a relevant filename, e.g. “2017 JCTC Report Calculations.xlsx.”

STEP THREE:  Once you complete the spreadsheets, you will need to upload both of them to the City’s secure Sharepoint site. The City's Sharepoint site includes a folder for your Company to upload these files and gives the City access to them. You can access that folder using the link provided in your annual report request email from the City.  

Only people with this link can access your company's folder on the City's Sharepoint site. City staff from Community and Economic Development and the Income Tax Division will access your data from Sharepoint to complete the verification step below.

STEP FOUR: The next step is to complete and submit online the Annual Progress Report. You can access this form using the framed form above on this page. Find the frame with "PLEASE ENTER YOUR CONTRACT NUMBER HERE" and enter the Contract Number that was provided in your annual report request email from the City.

Your Contract Number identifies your JCTC/PIR Agreement and opens the submission form for that Agreement. This form ensures that the data is linked to that Agreement and its requirements. It includes your commitments "of record" from our central database – these are based on your Agreement. The remainder of the form asks for your input on 2017 figures; most of these can be found on your 2017 Calculations spreadsheet submitted above.

Complete the form using the input boxes. When you are finished, check your work and then check the box at the bottom of the page and include your name and title. By checking the box and providing your Name and Title, you are certifying that the information you are providing is complete and accurate. Click SUBMIT to submit the report.

If you start entering data into the form and have to stop or you leave your computer and it times out, simply enter the form again the same way. The data you entered should still be in the form. Once you click SUBMIT, the report will be saved. If you need to make changes after submitting, you will need to start over with a new form. We will use the most recent submission as your annual report.

If you wish to print your form (or save it), your browser should provide you the ability to print the ”frame” that the report is in. Right-click in the frame and look at the Menu options available. One of them should be to open the frame in its own web page, and/or to print the frame. You should keep a copy of your submitted form at least until you receive verification from the City that it was received (usually your tax credit or retention compliance letter).

STEP FIVE: This step is the Signature Form. All companies with a JCTC or PIR Agreement must certify that the submission of the annual report is accurate and complete by having it signed by the Chief Executive Officer and Chief Financial Officer of the Company. Many Agreements also require that these reports are signed by an independent certified public accountant licensed to do business in the state of Ohio (an ICPA). The ICPA certifies the accuracy and completeness of the report for this tax year and all previous tax years in which the reports were not certified by an ICPA.
 
Click on Signature Form here to download the Signature Form and have it signed by all appropriate parties. Scan and upload the form to the Sharepoint site as you did for the spreadsheets above, or mail it to Michael Banish, Data Integrity Manager, Department of Community and Economic Development, City of Cincinnati, 805 Central Avenue, Suite 700, Cincinnati, OH 45202.

STEP SIX:  This is the City’s Verification Process. The City’s Income Tax Division will access your Employee Listing and Calculations spreadsheets from Sharepoint and the Annual Progress Report form and compare the employment, payroll, and tax withholding figures to your 2017 W-3 and W-2s. If the figures can be verified, Income Tax will send a memo to the Department of Community and Economic Development (DCED) verifying the accuracy of your data.
 
Using the information submitted, DCED will determine your compliance status and confirm your tax credit eligibility. DCED will send you a letter verifying your tax credit (if your Tax Credit Term has not expired) or your compliance status (if you are in the Employee Retention Period). If you are in default of the Agreement (i.e., not in compliance), you will receive a Notice of Default and have 30 days to resolve any issues.

STEP SEVEN: When you complete your Business Tax Return and submit it to Income Tax Division, be sure to include your credit on the relevant line (on 2017’s Business Tax Return form it was line 9b.). Attach your tax credit verification letter from DCED to your return when you submit it.

Tax credits are typically good for up to five years (check your Agreement). If your Agreement refers to a refundable tax credit, and you complete and submit the business tax return properly, the City’s Income Tax Division will send you a refund check if a refund is due.

THIS COMPLETES THE JCTC/PIR ANNUAL REPORTING PROCESS

If you have any questions, please contact Michael Banish at the email address or phone number below.

Monitoring & Compliance Reporting Contacts

Clifton Pendergrass
Division Manager
513-352-3305
clifton.pendergrass@cincinnati-oh.gov

 
Michael Banish
Data Integrity Manager
513-352-1958
michael.banish@cincinnati-oh.gov

Monitors JCTCs, PIRs
Carmen Gulliford
Administrative Specialist
513-352-4545
carmen.gulliford@cincinnati-oh.gov

Monitors Commercial and Residential CRAs