Historic Rehabilitation Tax Credit Transactions After The Safe Harbor

Lenders, Developers and Borrowers were all frustrated by the chilling effect that revenue rulings and court cases had on Historic Rehabilitation loans in 2013, causing delays in closings and delays in admitting Federal tax credit investors as partners of the Borrower. After issuance of Revenue Procedure 2014-12, a Safe Harbor for Historic Tax Credit Transactions, a resurgence of Federal investor interest is now apparent; however, structuring loans for these transactions after the Revenue Procedure involves tackling new territory.

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Small Businesses Remain Targets of Immigration and Customs Enforcement

To verify identity and employment eligibility, federal law requires every employer to timely complete and maintain a Form I-9 for each employee. Some small businesses mistakenly believe that they are not a likely target for enforcement of these requirements because they do not employ a large work force or they employ no foreign nationals. To believe this is a mistake.

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