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Federal Tax Incentives for Historic Preservation

OnDemand Webinar (94 minutes)

Gain an understanding of the tax/regulatory rules used with this tax incentive and how best to use HTCs for both large and small projects.The Federal Historic Rehabilitation Tax Credit (HTC) has grown into a key financing tool for economic development, historic preservation and neighborhood revitalization. Combined in many areas with available state historic rehabilitation tax credits, HTCs have been used to rehabilitate historic city centers, theatres, warehouses and other historic buildings across the country. This topic will start with the basic tax and regulatory framework for HTCs. Explore the basic deal structures being used today, as well as discuss potential stumbling blocks, including recapture risks and tax exempt structuring issues. Discuss several court cases involving HTCs, including the Historic Boardwalk Hall case. IRS Guidance regarding the Historic Tax Credit Safe Harbor - Revenue Procedure 2014-12, 50(d) income issues and recent changes made to the program by the Tax Cuts and Jobs Act of 2017. The topic will explain how to monetize the tax credits from both the developer and the investor perspective following the recent IRS Guidance, and will conclude with a brief discussion of other tax incentives that can be used in conjunction with HTCs. Gain an understanding of the tax/regulatory rules and structures being used in conjunction with this tax incentive, strategies for monetizing the HTCs to bring needed capital into projects, information how best to use HTCs for both large and small projects, the most up-to-date knowledge regarding Revenue Procedure 2014-12, 50d income issues, the tax transition rules and updates to the program made by the recent tax legislation.

Authors

Kathryn Galbraith Day, Klein Hornig LLP Daniel J. Kolodner, Klein Hornig LLP Nicholas J. Ratti, CohnReznick LLP

Agenda

Laying the Foundation: The Basic Tax and Regulatory Rules Governing Historic Rehabilitation Tax Credits

• A Record of Successful Development: Why Historic Tax Credits Work

• The National Park Service Rules vs. the IRS Rules

• Exploring the National Park Service Rules: The Historic Preservation Certification Application

• Exploring the IRS Rules

• Qualified Rehabilitation Expenditures

• Calculating the Allowable Tax Credit

• When and How Can the Tax Credit Be Taken?

• Tax Exempt Issues: Potential Stumbling Blocks

• Recapture of the Tax Credit

Structuring the Tax Credit

• Single Entity Structures

• Lease Pass-Through Structures

Recent Developments in Historic Tax Credits Including Up-To-Date IRS Guidance

• Renew the Transition Rules and Changes Made to the Program Under Recent Tax Legislation

• IRS Revenue Procedure 2014-12: Safe Harbor Guidance From the IRS; Review and Explanation of the IRS Guidance

• Puts and Calls or Flips: How Do I Exit My Transaction?

• Most Recent IRS Guidance on 50d Income Issues

- Monetizing Historic Rehabilitation Tax Credits

• What Does the New Guidance Mean for Monetizing Historic Rehabilitation Tax Credits?

• How to Find Investors for Your Project After the Recent IRS Guidance

• Maximizing Value

• Getting (and Selecting) the Best Offer

Monetizing Historic Rehabilitation Tax Credits

• What Does the Recent Tax Legislation Mean?

• How to Find Investors for Your Project After Tax Reform

• Maximizing Value

• Getting (and Selecting) the Best Offer