Novogradac Historic Tax Credit Conference Marriott Riverwalk San Antonio, Tex. #NovocoHTC. September 17-18,

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1 1

2 Brad Elphick 2

3 Direct Investment (Single Tier) Structure State Investor (where applicable) 1-5% if applicable Federal Investor 1% 94-99% GP/ Sponsor Property Owner (Landlord) 3

4 Lease Pass-Through Structure State Partner GP/ Sponsor Federal Investor 85-90% 99% 1-5% if applicable 10% Property Owner (Landlord) No basis reduction GP/ Sponsor Master Tenant 1% 4

5 HTC Lease Pass-through Structure Chart Loan A (State Bridge Loan) Manager, LLC (Managing Member) Federal HTC Investor 89% Equity Member Development Fee Federal HTC 99% Equity Member First Mortgage State Loan 1% Equity Member (Landlord) Pays debt service Federal HTCs rent payments 10% Equity Member Master Tenant, LLC (Master Tenant) pays operating expenses 1% Equity Member Rent payments received directly from tenants Master Tenant Manager, LLC (Managing Member) Loan B (Federal Bridge Loan) State HTCs State HTC Investor Apartment Leases Retail Leases 5

6 States with Tax Credits 6

7 States with Largest Number of Projects with Total Development Costs SHTC Program State Projects TDC (Millions) Yes Missouri 1,150 $4,569 Yes Virginia 954 $2,565 Yes Ohio 697 $1,815 No Pennsylvania 493 $2,555 Yes North Carolina 484 $1,146 Yes Louisiana 423 $1,548 Yes Massachusetts N/A $2,811 Yes New York 266 $2,471 No California N/A $1,987 No Michigan* 240 $1,

8 Key Legal Citations IRS CCA Massachusetts State Tax Credits Stated the IRS litigation position was that allocation of state low-income and historic tax credit were property, capital assets and had zero basis. IRS CCA Stated the IRS litigation position that certificated credits were capital assets, property and had a zero basis. Virginia Historic Tax Credit Fund 2001 LP v. Comm. 107 AFTR 2d US Court of Appeals Held the Allocated Credits were Sold as Section 707 Disguised Sale. No income was realized. Subsequent litigation dealt with the income tax effect. 8

9 Historic Boardwalk Hall ( HBH ) Third Circuit 2012 Decision The HBH Revenue Procedure simply stated the investor lacked a meaningful stake in either the success or failure of the partnership, so the investor was not a bona fide partner. Bad facts included: Investor capital not needed for construction Federal HTCs were an after-thought A governmental GP Exit pre-funded Lots and lots of other bad facts 9

10 Key Legal Citations Revenue Procedure Three times the Revenue Procedure made note of state tax credits: i. This Revenue Procedure does not apply to... state credit transactions. ii. "It does not indicate the circumstances under which the Service may challenge...the circumstances under which a transfer of state credits by a partnership may be treated as a disguised sale..." iii. "The Treasury Department and Service do not intend the inclusion of any particular criteria in the Safe Harbor to be an indication... of our views of the significance of that criterion with respect to any... state tax credit transactions.. Issued late 2013, and amended early 2014, to provide a safe harbor for partner status Negotiation with Treasury and IRS were done by the Historic Tax Credit Coalition. 10

11 Key Legal Citations (Continued) Gateway Hotel Partners, LLC v. Commissioner, TC Memo Final decision just entered. The structure the MO HTC certificate was a distribution of property against a GP capital account. Partial win for the taxpayer. Route 231 LLC v. Commissioner TC Memo Held the VA conservation tax credits, transferable as allocations, were property, and a disguised sale occurred. Tempel v. Commissioner, 10 th Circuit, 2014 Upheld the IRS that Colorado easement tax credits were taxable on property with zero basis on the date of the gift. SWF Real Estate, LLC, TC Memo Held the VA Conservation Credits were a disguised sale, and year of realization was the year the credit documents were recorded and funded, not the next calendar year when the certificates were issued under economic benefit test. 11

12 Emerging Legal Principles Tax Principles Emerging State Tax Credits have a Federal Tax Incidence Income Realization by the Development Partnership or a Partner must follow The total gain needs to be 100 cents as state tax credits have a zero basis The 704(b) Rules apply 12

13 Various Structures Available I. Pay tax on sale of state credits II. Donation structures Massachusetts Model GP donates credits to an unrelated party, and when the certificate or allocation is received, the charity sells the credit, and loans funds to the partnership with various sequential structures for that loan. 13

14 Various Structures Available III. Special Purpose Loss Corporation Loss Corporations are specially allocated state tax credit. Can be for-profit, non-profit, or exempt organizations. Upon receipt of the allocation Corporation swaps for a Certificate, which is sold, and funds contributed as capital with income recognition by the Corporation. Levine Injunction Case (U.S. District Court, Southern District, NY) Involves an alleged abusive tax scheme to use loss entities with fabricated losses, and not generated from active businesses. 14

15 Various Structures Available IV. HBH Impacts Allocations must be to a partner. Capital from State partner. Variable return Entrepreneurial risk Guarantees from Developers 15

16 Brad Elphick 16

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