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Presented by:

Strategic Partner:

Historic Tax Credits -
The New Frontier

Chicago, IL June 5- 6, 2014


To download presentations from this conference, click here.


The IRS guidance on Historic Boardwalk Hall (Revenue Procedure 2014-12) has been a game changer for the historic tax credit (HTC) industry. Compliance with the Safe Harbor created by the Rev. Proc. is essential to deal structuring in the HTC space. The first waves of Safe Harbor–compliant deals have closed, and the industry is wrestling with some aspects of the guidance that have proven to be difficult to apply in practice. Experienced investors, developers, and practitioners on the front lines of today’s HTC transactions will gather in Chicago to take a comprehensive look at the current environment and lessons learned from the first generation of Safe Harbor–compliant transactions, including:

  • Structure Risk. Investors now take structure risk, but what does this really mean? What can be guaranteed, and how damages for lost credits can be measured without running afoul of the Safe Harbor. How have pricing and deal terms responded to the new risk allocation?
  • Developer fees, management fees, incentive fees, lease terms, and other arrangements. They all must be reasonable compared to fees, lease terms, or other arrangements for non-HTC real estate developments. How are investors underwriting this requirement?
  • Combining HTCs with New Markets Tax Credits, Low Income Housing Tax Credits, and loans from affiliates. What is a separately negotiated, distinct economic arrangement, and how can you show it?
  • Timing and amount of capital contributions. How much must be fixed? What can be adjusted? How are phased rehabs being dealt with?
  • Flips and exits in the new environment. What are the different ways that they can be handled? Also, the issue of 50(d) income is now squarely out in the open. Where does the IRS stand on guidance?

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