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Federal Tax Incentives for Historic Preservation

Understand the latest updates to the Federal Historic Rehabilitation Tax Credit, including changes made by the Tax Cuts and Jobs Act of 2017.

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.

Runtime: 90 minutes
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Why Lorman?

Over 31 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

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
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Why Lorman?

Over 31 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Credits

OnDemand Webinar

Applications have not yet been submitted for Delaware, Idaho, Kentucky, Ohio, Oklahoma, South Carolina, and Wyoming CLE for this course. However, if you are interested in obtaining CLE for any of the listed states or have any additional credit questions please email us at [email protected] or call us at 866-352-9540.

This course was last revised on March 12, 2018.

Call 1-866-352-9540 for further credit information.

  • AICP 1.5 including Law 1.5
     
  • This course has been approved by the American Planning Association for 1.5 hours of CM credit for AICP members. Additionally, this course has been approved for 1.5 hours of Law Credit.
     
  • AK CLE 1.5
     
  • Alaska attorneys may receive 1.5 hours of continuing legal education for completing this program. Please contact the Alaska Bar Association or go to www.alaskabar.org for details regarding reciprocity with other states.
     
  • AL CLE 1.5
     
  • This course or a portion thereof has been approved by the Alabama State Mandatory Continuing Legal Education Commission for a maximum of 1.5 hours credit.
     
  • Arizona CLE 1.5
     
  • The Arizona State Bar does not pre-approve or pre-certify MCLE programs. However, records of this program and attendance will be maintained by Lorman Education Services for auditing purposes. This activity may qualify for up to 1.5 hours toward your annual CLE requirement for the State Bar of Arizona.
     
  • CO CLE 2.0
     
  • This program may qualify for 2.0 credit hours through the Colorado Supreme Court Board of Continuing Legal and Judicial Education through reciprocity. This course is accredited in other jurisdictions such as New Jersey. To receive CLE credit for this program, a home study affidavit must be submitted to the Supreme Court Board of Continuing Legal and Judicial Education.
     
  • CT CLE 1.5
     
  • Neither the Connecticut Judicial Branch nor the Commission on Minimum Continuing Legal Education approve or accredit CLE providers or activities. This course has been approved for CLE credit in jurisdictions aside from CT and therefore it automatically meets the content and delivery requirements in Connecticut. Credit is based on a 60 minute credit hour and shall be awarded as follows: 1.5 CLE credit(s).
     
  • HI CLE 1.5
     
  • This program was approved by the Hawaii State Board of Continuing Legal Education for 1.5 CLE credit hours.
     
  • IL CLE 1.5
     
  • This course was approved for a total of 1.5 hours of MCLE Credit by the Illinois MCLE Board.
     
  • ME CLE 1.5
     
  • This course has been approved by the State of Maine Board of Overseers of the Bar. Lawyers who complete this course shall receive 1.5 hours of CLE credit under M. Bar R. 12.
     
  • MS CLE 1.5
     
  • This program has been approved by the Mississippi Commission on Continuing Legal Education for a maximum of 1.5 credit hours.
     
  • MT CLE 1.5
     
  • This program has been approved by the Montana Commission of Continuing Legal Education for a total of 1.5 CLE credits.
     
  • ND CLE 1.5
     
  • North Dakota CLE policy does not allow for pre-approval of any self-study courses. This course may qualify for up to 1.5 hours of CLE credit.
     
  • NH MCLE 1.5
     
  • NH MCLE does not approve or accredit CLE activities for the NH Minimum CLE requirement. Lorman Education Services believes this course meets the requirement of NH Supreme Court Rule 53 and may qualify for CLE credit(s). Program Length: 90 Minutes.
     
  • NJ CLE 1.8
     
  • This program has been approved by the Board on Continuing Legal Education of the Supreme Court of New Jersey for 1.8 hours of total CLE credit.
     
  • NV CLE 1.5
     
  • This program has been approved by the Nevada Board of Continuing Legal Education for 1.5 CLE hours.
     
  • PA CLE 1.5
     
  • This Distance Learning program has been approved by the Pennsylvania Continuing Legal Education Board for 1.5 hours of substantive law, practice and procedure CLE credit.
     
  • RI CLE 1.5
     
  • This program has been approved by the Rhode Island Mandatory Continuing Legal Education Commission for 1.5 hours of CLE credit.
     
  • TN CLE 1.5
     
  • This program has been approved as a distance learning format by the Tennessee Commission on Continuing Legal Education for a maximum of 1.5 hours of credit.
     
  • VT CLE 1.5
     
  • This program has been approved by the Mandatory Continuing Legal Education Board of Vermont for 1.5 hours of self-study CLE credit.
     
  • WA CLE 1.5
     
  • This program has been approved by the Washington State Board of Continuing Legal Education for 1.5 hours of A/V credit under the Law & Legal Procedure category.
     
  • WI CLE 1.5
     
  • This program has been approved by the Board of Bar Examiners for 1.5 hours for use toward the Wisconsin Mandatory CLE requirement.
     
  • WV MCLE 1.8
     
  • This program has been approved by the West Virginia State Bar MCLE Commission for 1.8 MCLE hours.
     

To earn each credit Lorman offers through the OnDemand learning platform, you need to watch 100% of the program. Also, for certain credits you will need to fulfill additional requirements which will be displayed on the "credits" tab when viewing the course.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

Audio & Reference Manual

  • Arizona CLE 1.5
     
  • CA MCLE 1.5
     
  • CT CLE 1.5
     
  • GA CLE 1.5
     
  • HI CLE 1.5
     
  • IL CLE 1.5
     
  • ME CLE 1.5
     
  • MT CLE 1.5
     
  • NJ CLE 1.8
     
  • NV CLE 1.5
     
  • VT CLE 1.5
     
  • WA CLE 1.5
     
  • WV MCLE 1.8
     
The CLE Code is ONLY a requirement when applying for CLE Credit in California (for participatory credit), Kansas, New Jersey or New York. Other states do not need to supply the CLE Code to apply for CLE credit.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

MP3 Download

  • Arizona CLE 1.5
     
  • CA MCLE 1.5
     
  • CT CLE 1.5
     
  • HI CLE 1.5
     
  • IL CLE 1.5
     
  • ME CLE 1.5
     
  • MT CLE 1.5
     
  • NJ CLE 1.8
     
  • NV CLE 1.5
     
  • VT CLE 1.5
     
  • WA CLE 1.5
     
  • WV MCLE 1.8
     
The CLE Code is ONLY a requirement when applying for CLE Credit in California (for participatory credit), Kansas, New Jersey or New York. Other states do not need to supply the CLE Code to apply for CLE credit.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

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Why Lorman?

Over 31 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Faculty

Kathryn Galbraith Day

Kathryn Galbraith Day

Klein Hornig LLP

  • Partner in Klein Hornig LLP’s Boston, Massachusetts office
  • Focuses her practice on federal and state income taxation of corporate, flow-through, and tax-exempt entities, as well as individuals
  • Represents developers, syndicators and investors in federal and state tax credit transactions, including historic, new markets and low-income housing tax credits
  • Has extensive experience representing nonprofit organizations
  • Well-versed in the law of tax-exempt organizations, including the rules governing private foundations, various federal and state reporting requirements, and the tax on unrelated business income
  • LL.M degree, Boston University School of Law; J.D. degree, Boston College Law School; B.A. degree, The College of William & Mary, summa cum laude
  • Can be contacted at 617-224-0627 or [email protected]
Daniel J. Kolodner

Daniel J. Kolodner

Klein Hornig LLP

  • Partner in Klein Hornig LLP’s Boston, Massachusetts office
  • Concentrates his practice on community development finance, specifically the use of tax incentives as means for financing community revitalization projects, with a focus on new markets tax credits and historic tax credits
  • Extensive experience in structuring transactions involving the use of new markets tax credits, historic tax credits and low income housing tax credits, as well as associated state tax credits
  • Practice focuses on assisting developers and tax-exempt entities, such as health centers, charter schools and theatres, in taking advantage of new markets tax credits and historic tax credits
  • Frequently speaks at national and local conferences on the topic of historic tax credits and new market tax credits, as well as other federal, state and local tax incentives
  • Recent guest lecturer on new markets tax credits and historic tax credits at the MIT Center for Real Estate in Cambridge, Massachusetts
  • Can be contacted at 617-224-0617 or [email protected]
Nicholas J. Ratti

Nicholas J. Ratti

CohnReznick LLP

  • Principal in CohnReznick LLP’s (formerly Reznick Group PC) Real Estate Consulting Practice in Boston, Massachusetts
  • More than 10 years of experience in the tax credit industry
  • Currently responsible for developing and evaluating transaction structures, providing tax compliance advice, evaluating tax credit recapture or tax-loss reallocation issues, strategizing post compliance period exits and providing syndication advisory services
  • Extensive experience structuring a wide range of low-income housing, historic and new market tax credit transactions for his developer and investor clients
  • Prior to joining CohnReznick LLP, he held positions as an accountant for Fidelity Investments and as a senior accountant for Ziner Kennedy and Lehan, both based in Boston
  • B.S. degree in accounting and finance, Providence College
  • Can be contacted at 617-648-1405 or [email protected]
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Why Lorman?

Over 31 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

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Pay once and get a full year of unlimited training in any format, any time!

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Product ID: 402200
Published 2018
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