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.
Agenda
Faculty
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
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]
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]
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