Novogradac LIHTC Working Group Comments on Disaster Relief

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Letter Calls for Clarification in Guidance to Confirm Disaster Relief for Tax-Exempt Bond Financed Affordable Rental Housing

Members of the LIHTC Working Group on March 28, 2014 sent a letter to the Assistant Secretary for Tax Policy at the Treasury Department requesting guidance for temporary relief for tax-exempt bond financed Low-Income Housing Tax Credit (LIHTC) properties that suffer a casualty loss due to a presidentially declared disaster.

“The need for clearer guidance regarding temporary disaster relief for properties earning LIHTCs through a tax-exempt bond issuance is an important matter to which the LIHTC Working Group can bring attention as it works to resolve technical and administrative LIHTC program issues experienced by members of the group,” said Stacey Stewart, CPA, a partner in Novogradac & Company LLP’s Dover, Ohio office who leads the LIHTC Working Group’s efforts. “The technical expertise of our members is one of the LIHTC Working Group’s key assets, as it allows us to address needs like this on behalf of the affordable housing community.”

In its letter to Treasury, the LIHTC Working Group notes that while Revenue Procedure 2007-54 provides temporary relief to LIHTC properties, the guidance makes specific reference to 9 percent LIHTC properties, but contains no explicit reference to tax-exempt bond financed tax credit properties . Therefore, the LIHTC Working Group has asked the Treasury Department to provide guidance that clearly states that the guidance applies to LIHTC properties financed by tax-exempt bonds.

“We value the opportunity to ask the Treasury Department to confirm the applicability of temporary disaster relief guidance to tax-exempt bond finance LIHTC properties,” said Michael J. Novogradac, CPA, managing partner in the firm’s San Francisco office and the LIHTC Working Group’s adviser on industry and governmental affairs.

For details and a copy of the letter, please go to The LIHTC Working Group was established by Novogradac & Company LLP in 2008 to provide a platform for LIHTC industry participants to work together to resolve technical and administrative LIHTC program issues. Members meet monthly via conference call to provide input regarding pending action items as agreed to by the members of the group. Comments and suggestions generated during the group discussions are agreed to and submitted in writing directly to Treasury, the Department of Housing and Urban Development and/or various state agencies. For more information, visit or email lwg(at)novoco(dot)com.

Novogradac & Company LLP was founded in 1989, and has since grown to more than 400 employees and partners in offices in San Francisco and Long Beach, Calif.; the Washington, D.C., Atlanta, Ga., Detroit, Mich., Kansas City, Mo. and Seattle, Wash. metro areas; St. Louis, Mo.; Boston, Mass.; Austin, Texas; Dover, Columbus and Cleveland, Ohio; New York, N.Y. and Portland, Ore. Specialty practice areas include tax, audit and consulting services for tax-credit-assisted multifamily and affordable housing, community revitalization and rehabilitation of historic properties. Other areas of expertise include military base redevelopment, preparation and analysis of market studies and appraisals of multifamily housing investments and renewable energy tax credits.

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Stacey Stewart
Novogradac & Company LLP
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