Schedule G Refunds

Eligible taxpayers were required to file refund claims between May 15, 2024, and December 2, 2024.  Eligible taxpayers included:

• Taxpayers who paid the franchise tax on the property measure (Schedule G) for tax years ending on or after March 31, 2020, for which a return was filed with the Department on or after January 1, 2021, and
• Taxpayers who timely filed a claim under Tenn. Code Ann. § 67-1-1802 prior to January 1, 2024, that alleged the franchise tax was unconstitutional by failing the internal consistency test.

Yes, the Department mailed multiple notification letters to all taxpayers it identified that might have been eligible for a refund. Regardless of whether taxpayers received a notification letter, we also encouraged taxpayers to review their records and/or consult a tax professional to determine if they might qualify for a refund.

To obtain a refund, taxpayers were required to file amended franchise and excise tax returns for the affected tax years and file a Claim for Refund of Franchise Tax Paid on Property Measure (Schedule G) form. The amended returns and refund claims had to be submitted by December 2, 2024. 

Public Chapter 950 (2024) established November 30, 2024 as the deadline for refund claims. Because that date fell on a Saturday, taxpayers could submit their amended returns and the special refund claim form until December 2, 2024. The Department accepted electronic filings on December 2 and filings submitted by mail with a December 2 postmark date.

No. Public Chapter 950 (2024) did not provide any authority for extending the deadline. 

Pursuant to Tenn. Code Ann. § 67-1-114, the Department did accept claims filed by May 1, 2025, but only for taxpayers whose primary location address was in one of fourteen specified Tennessee counties designated as federal disaster areas.  See Tenn. Dept. Rev. Important Notices No. 24-09 (Oct. 2024) and No. 25-02 (March 2025).  Tenn. Code Ann. § 67-1-114 provided no further authority for other extensions. 

To obtain a refund, taxpayers were required to file amended franchise and excise tax returns for the affected tax years and file a Claim for Refund of Franchise Tax Paid on Property Measure (Schedule G) form by December 2, 2024. 

If either step was not completed by December 2, 2024, no refund was or could be paid.

Public Chapter 950 (2024) required taxpayers to file a claim for refund “on a form prescribed by the commissioner exclusively for the purpose of seeking a refund pursuant to this section.”   To obtain a refund, taxpayers were required to file amended franchise and excise tax returns for the affected tax years and file a Claim for Refund of Franchise Tax Paid on Property Measure (Schedule G) form by December 2, 2024. 

If either step was not completed by December 2, 2024, no refund was or could be paid.

Schedule G is not required for tax years ending on or after January 1, 2024.  Taxpayers filing for tax periods ending November 30, 2024, or earlier will see a line on the return to report their Schedule G figures but are not required to complete Schedule G.  Instead, you should report franchise tax on your original return based on Schedule F figures and leave Schedule G blank.

For tax years ending on or after January 1, 2024, taxpayers will calculate franchise tax on net worth using Schedule F. 

However, taxpayers may make an election to calculate franchise tax for tax years ending on or after January 1, 2024, based on the minimum measure using Schedule G if that election results in a higher tax levied for the tax period than would result if the tax were calculated based on net worth.

For tax years ending before January 1, 2024, taxpayers must calculate franchise tax on the greater of the company’s net worth or the book value of real or tangible personal property owned or used in Tennessee.

For tax years ending on or after January 1, 2024, franchise tax will be calculated on net worth using Schedule F. 

For tax years ending before January 1, 2024, franchise tax will be calculated on the greater of the company’s net worth (Schedule F) or the book value of real or tangible personal property owned or used in Tennessee (Schedule G).

For tax years ending on or after January 1, 2024, franchise tax will be calculated on net worth using Schedule F. 

For tax years ending before January 1, 2024, franchise tax will be calculated on the greater of the company’s net worth (Schedule F) or the book value of real or tangible personal property owned or used in Tennessee (Schedule G).

For returns filed for tax years ending in 2023, taxpayers had two options for pursuing a claim for refund:

1. Complete Schedule F and Schedule G, then calculate franchise tax based on the greater of Schedule F net worth or Schedule G property, then request a refund of franchise tax pursuant to the refund procedure, including the amended return and Claim for Refund of Franchise Tax Paid on Property Measure (Schedule G) form by the deadline, or
2. Complete Schedule F and calculate franchise tax based on Schedule F net worth, then submit a completed Pro Forma Schedule G and a Claim for Refund of Franchise Tax Paid on Property Measure (Schedule G) form by the deadline.

If a taxpayer did not adhere to one of the two options above and the value of Schedule G was higher, the taxpayer may be subject to the assessment of additional franchise tax for 2023.  To avoid that potential, taxpayers are encouraged to amend their 2023 return to reflect the correct franchise tax base under the law that remains in effect for that period.

Amended returns and refund claims filed by taxpayers are confidential tax information that the department is prohibited by law from disclosing or making available for inspection to the public.

However, the legislation that authorized the department to issue these refunds required the department to publish the name of each taxpayer issued a refund and the applicable range corresponding to the total amount refunded to the taxpayer in a list on the department’s website from May 31, 2025 through June 30, 2025.  The list of taxpayer names was posted as required during that time period, grouped per the legislation as follows:  $750 or less; $751 - $10,000; more than $10,000, and “pending.”