196.081 CREDIT FOR TAX PAID TO OTHER OHIO MUNICIPALITIES OR TO OHIO JOINT ECONOMIC DEVELOPMENT DISTRICTS OR JOINT ECONOMIC DEVELOPMENT ZONES; CREDIT OF TAX PAID ON INCOME GENERATED OUTSIDE OF OHIO.
   (A)   Every individual who resides in the City but who receives net profits, qualifying wages, or other municipal taxable income for work done or services performed or rendered in Ohio but outside the City, and who is liable to and has paid to another municipality or a joint economic development zone created under section 715.691 or a joint economic development district created under section 715.70, 715.71, or 715.72 of the Ohio Revised Code an income tax on the same income taxable and taxed under this Chapter, shall be allowed a credit in an amount equal to fifty percent (50%) of the tax levied by the other Ohio municipality or an Ohio joint economic development zone created under section 715.691 or an Ohio joint economic development district created under section 715.70, 715.71, or 715.72 of the Ohio Revised Code. Notwithstanding the foregoing, in no event shall such credit exceed fifty percent (50%) of the tax imposed by this chapter on the same income. There shall be no carry forward or carry backward of such tax credit to any tax year other than the tax year in which the tax was paid to such other Ohio municipality or an Ohio joint economic development zone created under section 715.691 or an Ohio joint economic development district created under section 715.70, 715.71, or 715.72 of the Ohio Revised Code.
 
   (B)   Taxpayers shall be allowed the credits established under Ohio Revised Code Sections 718.021, 718.121, but only to the extent as limited by Ohio Revised Code Chapter 718.
 
   (C)   Taxpayers are allowed a nonrefundable credit against the tax imposed under this Chapter on income generated outside of Ohio, with the credit to be in the amount of 100% of the non-Ohio municipality authorized tax paid on that same income in the authorizing non-Ohio municipality in which the income was generated; provided the tax for which the credit is claimed is of the same nature or having the same practical effect as the tax imposed under this Chapter. Notwithstanding the foregoing, in no event shall such credit exceed one hundred percent (100%) of the tax. imposed by this chapter on the same income. The burden of proof is on the taxpayer to show that the tax for which the taxpayer claims a credit is of the same nature or having the same practical effect as the tax imposed under this Chapter and that the tax for which the taxpayer claims a credit was imposed on the same income taxed by the City against which the taxpayer is claiming a credit. The section applies only to income generated in the United States of America and is intended to and limited to preventing a violation of the Commerce Clause of the United States Constitution as prohibited in Comptroller of the Treasury of Maryland v. Wynne, 575 U.S. __ 135 S.Ct. 1787, 191 L.Ed.2d 813, 25 Fla.L.Weekly Fed. S 233. (2015)