Midwest Lenders Association Conference Federal and State Tax Credit Programs October 13, 2015
Federal and State Tax Credit Programs Low-income housing tax credits Historic rehabilitation tax credits New markets tax credits 2
Equity market is robust – equity is in excess of available credits Type of investors Financial insititutions Syndicators Financial institutions Insurance companies Other widely-held C corporations CRA vs. Non-CRA market Low-Income Housing Tax Credits 3
4 First Mortgage Debt (Lender) Sample Project, LLC (Landlord) Managing Member.01% Federal Investor 99.99% Debt Repayment Debt $0 Equity $0 Equity $0
IRS Safe Harbor (Rev. Proc ) Type of investors Financial insititutions Other widely-held C corporations Syndicators Financial institutions Other widely-held C corporations Historic Rehabilitation Tax Credits 5
Tax Structures Single tier structure Master lease structure IRC Section 50(D) income Historic Rehabilitation Tax Credits 6
7 Sample Project, LLC (Landlord) First Mortgage Debt (Lender) Managing Member 1% Federal Investor 99% Debt Repayment Debt $0 Equity $0 Equity $0
Historic Rehabilitation Tax Credits 8 Sample Project, LLC (Landlord) Sample Project Master Tenant, LLC (Master Tenant) 1% First Mortgage Debt (Lender) Federal LIHTC Member 97.99% Managing Member.01% Managing Member.01% Federal Historic Investor 99.99% State Historic entity 1% Debt Repayment Debt $0 Equity $0 Equity $0 Equity $0
Statutorily expired after 2014 – part of “extenders package” currently in Congress Leverage lender concept Complex structure Expensive capital Non-profits are the best sponsors/owners New Markets Tax Credits 9
10 Investment Fund (99.99%) Federal New Markets Investor (100%) ABC Bank Leveraged Loan CDE Managing Member.01% ABC Project (Fee owner - Landlord) (QALICB) XYZ Sub-CDE (100%) XYZ MM, LLC (99%) ABC Member (1%) Debt $8,400,000 Debt Services Debt $4,488,145 Equity $2,788,500 Debt Services Put Option $1,000 NMTC’s $4,290,000 Sub-allocatee Fee $188,500 CDE Fees $471,500 QEI $11,000,000 Debt – A Piece $8,400,000 Debt – B Piece $2,128,500 Debt Services Equity $100 Equity $192,659
Dave Herdlick Midwest Lenders Association Conference 11