SC SC Information Letter #19-2 2019-01-02

What are South Carolina's 2019 county tier rankings for the job tax credit, and which counties qualify for the tax moratorium and reduced fee-in-lieu investment (per SC IL #19-2)?

Short answer: SC Information Letter #19-2 sets the 2019 county designations that drive several South Carolina incentives. For the job tax credit, the 46 counties are ranked into Tiers I-IV (higher tiers = larger credit for less-developed counties): Tier IV includes Allendale, Bamberg, Barnwell, Chester, Clarendon, Dillon, Lee, Marion, Marlboro, Orangeburg, Union, and Williamsburg. For the tax moratorium under § 12-6-3367, the 2019 qualifying counties are Dillon, Jasper, and Marlboro. For the reduced ($1 million) minimum investment for the fee in lieu of property taxes, no county qualifies for 2019. The rankings apply to new full-time jobs created in tax years beginning in 2019 where the credit is first earned on or after January 1, 2019.

Apply this to your situation

This page answers the general question as of 2019. Ezel answers yours, under current South Carolina tax law, with citations.

Currency note: this ruling is from 2019
Subsequent statutory amendments, regulation changes, court decisions, or later rulings may have changed the analysis. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, rate, or position mentioned here.
Disclaimer: This is an official South Carolina Department of Revenue Information Letter. Per the Department, an Information Letter announces general information useful in complying with the laws administered by the Department and has NO precedential value. These county designations are set for 2019 and are recomputed annually from unemployment and per capita income data, so confirm the current-year rankings before relying on them. This summary is informational only and is not legal or tax advice.
About this page: The plain-English summary, reader guidance, and Q&A below were written by Ezel based on the official state tax ruling. The original ruling (linked on this page as a PDF) is the authoritative source for any reliance.
View original ruling (PDF)

Plain-English summary

This Information Letter publishes the 2019 county designations that South Carolina uses for three economic-development incentives. The designations turn on per capita income and unemployment data from the South Carolina Department of Employment and Workforce and the U.S. Department of Commerce.

Job tax credit — county tiers. The 46 counties are ranked into four tiers, with equal weight given to unemployment rate and per capita income under § 12-6-3360(B). Less-developed counties fall in higher tiers and earn a larger per-job credit. The rankings apply to new, full-time jobs created in tax years that begin in 2019 where the credit is first earned on or after January 1, 2019. Tier IV (the most-distressed group) is Allendale, Bamberg, Barnwell, Chester, Clarendon, Dillon, Lee, Marion, Marlboro, Orangeburg, Union, and Williamsburg. Tier I (the most-developed group) is Anderson, Beaufort, Berkeley, Charleston, Dorchester, Greenville, Lexington, Richland, Spartanburg, and York. Tiers II and III cover the remaining counties, listed in full in the letter.

Tax moratorium. Section 12-6-3367 grants a 10-year (15 years in certain cases) moratorium on corporate income or insurance premium taxes for qualifying taxpayers in the most-distressed counties. For 2019 the qualifying counties are Dillon, Jasper, and Marlboro.

Reduced fee-in-lieu investment. The normal minimum investment to qualify for a fee in lieu of property taxes is $2.5 million (Little Fee and Simplified Fee) or $45 million (Big Fee), reduced to $1 million in counties with very high unemployment. For 2019, no county qualifies for the $1 million minimum.

What this means for you

If you are creating jobs in South Carolina

Find your county's tier to gauge the per-job credit; the largest credits go to Tier IV counties. Remember the ranking applies to jobs first earning the credit on or after January 1, 2019.

If you are siting a capital-intensive project

Check whether the county is a 2019 moratorium county (Dillon, Jasper, Marlboro) and note that no county qualified for the reduced $1 million fee-in-lieu investment threshold this year.

Common questions

Q: Which counties are Tier IV (largest job tax credit) for 2019?
A: Allendale, Bamberg, Barnwell, Chester, Clarendon, Dillon, Lee, Marion, Marlboro, Orangeburg, Union, and Williamsburg.

Q: Which counties qualify for the tax moratorium in 2019?
A: Dillon, Jasper, and Marlboro.

Q: Does any county qualify for the reduced $1 million fee-in-lieu investment in 2019?
A: No county qualifies for 2019.

Subject

Job Tax Credit - County Rankings for 2019 Fee in Lieu of Property Taxes – Reduced Investment Counties Tax Moratorium – Qualifying Counties

Source

Original ruling text

STATE OF SOUTH CAROLINA

DEPARTMENT OF REVENUE
300A Outlet Pointe Blvd., Columbia, South Carolina 29210
P.O. Box 125, Columbia, South Carolina 29214

SC INFORMATION LETTER #19-2

SUBJECT:

Job Tax Credit - County Rankings for 2019
Fee in Lieu of Property Taxes – Reduced Investment Counties
Tax Moratorium – Qualifying Counties

DATE:

January 2, 2019

REFERENCE:

S. C. Code Ann. Section 12-6-3360 (2014; Supp. 2017)
S. C. Code Ann. Section 12-6-3367 (2014)
S. C. Code Ann. Section 12-44-30 (2014)
S. C. Code Ann. Section 4-12-30 (Supp. 2017)
S. C. Code Ann. Section 4-29-67 (Supp. 2017)

AUTHORITY:

S.C. Code Ann. Section 12-4-320 (2014)
S.C. Code Ann. Section 1-23-10(4) (2005)
SC Revenue Procedure #09-3

SCOPE:

An Information Letter is a written statement issued to the public to announce
general information useful in complying with the laws administered by the
Department. An Information Letter has no precedential value.

INTRODUCTION
The job tax credit, the tax moratorium, and the reduction in the minimum required fee in lieu of
property tax investment are dependent, in part, on per capita income and unemployment rate data
received from the South Carolina Department of Employment and Workforce and the United
States Department of Commerce.
The purpose of this information letter is to provide the county rankings for purposes of the job
tax credit, counties qualifying for the tax moratorium, and counties qualifying for the reduced fee
in lieu of property tax.
JOB TAX CREDIT – County Rankings
South Carolina’s 46 counties are ranked and designated annually for job tax credit purposes with
equal weight given to unemployment rate and per capita income as provided in South Carolina
Code Section 12-6-3360(B).

The final rankings of counties for new, full time jobs created in tax years that begin in 2019,
where the job tax credit was first earned on or after January 1, 2019, and increases in such jobs
are listed below.
TIER IV
Allendale
Bamberg
Barnwell
Chester
Clarendon
Dillon
Lee
Marion
Marlboro
Orangeburg
Union
Williamsburg

TIER III

TIER II

Abbeville
Calhoun
Cherokee
Chesterfield
Colleton
Darlington
Edgefield
Fairfield
Hampton
Horry
Jasper
McCormick

Aiken
Florence
Georgetown
Greenwood
Kershaw
Lancaster
Laurens
Newberry
Oconee
Pickens
Saluda
Sumter

TIER I
Anderson
Beaufort
Berkeley
Charleston
Dorchester
Greenville
Lexington
Richland
Spartanburg
York

TAX MORATORIUM – Qualifying Counties
South Carolina Code Section 12-6-3367, in part, grants a 10 year moratorium (15 years in certain
cases) on corporate income taxes or insurance premium taxes for qualifying taxpayers in a
county with an average annual unemployment rate of at least twice the state average during each
of the last two completed calendar years, based on the most recent unemployment rates available,
or in a county with one of the three lowest per capita incomes based on the average of the three
most recent years of available average per capita income data. The moratorium begins the first
full taxable year after the taxpayer qualifies in a county designated as a moratorium county.
For 2019, the following counties have been designated moratorium counties under South
Carolina Code Section 12-6-3367.

Dillon
Jasper
Marlboro

2

FEE IN LIEU OF PROPERTY TAXES - Reduced Investment Counties
The minimum required investment necessary to qualify for the fee in lieu of property taxes is
$2.5 million for the “Little Fee” and “Simplified Fee,” and $45 million for the “Big Fee.” See
South Carolina Code Sections 4-12-30(B)(3), 12-44-30(14), and 4-29-67, respectively. This
investment amount, however, is reduced to $1 million for a company investing in a county with
an average annual unemployment rate of at least twice the state average during each of the last
24 months, based on data available on November 1.
For 2019, no county qualifies for the $1 million minimum investment under the “Little Fee,”
“Simplified Fee,” and “Big Fee.”

3

Get today's answer for your situation

You just read a 2019 ruling on this question. Ezel checks current South Carolina tax law and answers your specific situation, with citations.

Opens in Ezel Pro. Every answer cites the authority it relies on.