syndication leasing structures how tax credits become capital: when and how to syndicate panel using...
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Syndication Leasing Structures
How Tax Credits Become Capital: When and How to Syndicate Panel
USING HISTORIC TAX CREDITS IN NEW YORK
June 24, 2009
The Rehabilitation Tax CreditsInternal Revenue Code Section 47
Tax Credit Investor LLC
Tax Credit Investor LLC
Tax Credit, LLC(Property Owner)
Tax Credit, LLC(Property Owner)
Tax Credit InvestorTax Credit Investor
Single Entity Structure
TenantsTenants
RentalPayments
Construction/Perm Lender
Construction/Perm Lender
Managing Member(Developer Affiliate)
Managing Member(Developer Affiliate)
HistoricTax Credit
Equity
99.99% Credits, Profits & Losses and Cash Flow
LoanProceeds
DebtService
Payments
.01% Credits, Profits & Losses, Fees and
Cash Flow
DeveloperEquity
DeveloperDeveloperDev.Fee
Tax Credit Investor LLC
Tax Credit Investor LLC
Master Tenant, LLC(Master Tenant)
Master Tenant, LLC(Master Tenant)
Landlord, LLC(Property Owner/Lessor)
Landlord, LLC(Property Owner/Lessor)
Master Lease/Credit Pass-Through Structure
Sub-Tenants/End Users
Sub-Tenants/End Users
RentalPayments
Construction/Perm Lender
Construction/Perm Lender
Managing Member(Developer Affiliate)
Managing Member(Developer Affiliate)
HistoricTax Credit
Equity
99.99% Credits, Profits & Losses, and Cash Flow
LoanProceeds
DebtService
Payments
.01% Credits, Profits & Losses, Fees and
Cash Flow
DeveloperEquity
>50% Profits & Losses, Fees and
Cash Flow
Pass-through of Historic Tax Credits & Share of Residual
Lease Payment &Equity Investment
<50% of Landlord Profits& Losses
Andrew Potts, Esq.401 9th Street, NWSuite 900Washington, DC 20004
202.585.8337202.585.8080 (Fax)
Thank You