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Federal Tax Incentives for Historic Preservation

Understand the latest updates to the Federal Historic Rehabilitation Tax Credit, including strategies to monetize the tax credits.

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 recent court cases involving HTCs, including the Historic Boardwalk Hall case, and we will review and explain the recently released IRS Guidance regarding the Historic Tax Credit Safe Harbor - Revenue Procedure 2014-12. 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 of how best to use HTCs for both large and small projects, the most up-to-date knowledge regarding Revenue Procedure 2014-12 as well as the most recent updates regarding 50d income issues.

Runtime: 90 minutes
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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 Two Types of Historic Rehabilitation Tax Credits: The 10% Credit and the 20% Credit
  • 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

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

Over 30 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

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

Audio & Reference Manual

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

MP3 Download

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

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More Program Information

Why Lorman?

Over 30 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

  • Attorney 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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Product ID: 399742
Published 2017
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