Our commercial finance team can provide the following services, among others, in connection with various state and federal tax credit programs:
Opportunity Zone (OZ) Tax Incentive
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Provide advice regarding OZ program and benefits.
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Organize Qualified Opportunity Funds (QOF) and Qualified Opportunity Zone Businesses (QOZB).
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Structure and advise clients with respect to QOF and QOZB investments.
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Negotiate and document qualified OZ real estate and operating business transactions.
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Provide guidance on compliance and reporting requirements related to OZ investments.
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Inform on legislative and administrative updates related to OZ tax incentive.
New Markets Tax Credits (NMTC)
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Organization and certification of Community Development Entities (CDEs).
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Assistance with applications for NMTC allocations and execution of NMTC Allocation Agreements.
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Evaluation and advice regarding prospective transactions and structuring.
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Negotiating terms with CDEs, tax credit investors, lenders or qualified businesses on behalf of our client in connection with an NMTC transaction.
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Preparation and/or review of all corporate and financing transaction documents and applicable opinion letters as needed to reach a successful closing.
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Reviewing and assisting with ongoing NMTC program compliance and unwind of NMTC transaction upon expiration of the tax credit compliance period.
Historic Tax Credits (HTC)
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Evaluation and advice regarding prospective transactions and structuring post Rev. Proc. 2014-12 and safe harbor guidelines.
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Addressing specific matters related to tax-exempt entities.
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Providing guidance regarding rehabilitation requirements, reasonable fees and services, IRC 50(d) income, partnership tax considerations and other HTC topics.
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Leading, documenting, negotiating and successfully closing the HTC transaction.
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Combining HTCs with other tax credits, including NMTCs and LIHTCs.
Low-Income Housing Tax Credits (LIHTC)
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Drafting and negotiating limited partnership and operating agreements to facilitate optimum, ongoing developer and investor relationships.
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Advise on complex tax structuring points and prepare and issue tax opinions.
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Work with tax-exempt bond issuers, lenders, credit agencies and local authorities to coordinate multiple financing components and documentation.
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Review and analyze syndicated investments and negotiate subscription and fund documents.
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Guide clients through year 15 dispositions and investor exits.