Historic Preservation Tax Credits The Next Level Master

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Historic Preservation Tax Credits The Next Level: “Master Tenant” Syndication

Historic Preservation Tax Credits The Next Level: “Master Tenant” Syndication

Single Entity Structure GP/Manager Investor 99. 9% Tax Credits 0. 1% Management Fees, etc.

Single Entity Structure GP/Manager Investor 99. 9% Tax Credits 0. 1% Management Fees, etc. Developer Development Fee Owner (LP or LLC) Fee Ownership Property Lease End User

Single Entity Structure Cash Flow: GP/Manager HTC Investor 1. Fixed Fees 0. 1% 2.

Single Entity Structure Cash Flow: GP/Manager HTC Investor 1. Fixed Fees 0. 1% 2. Gross Revenues Management Fees, etc. 99. 9% Tax Credits 1. HTC Developer Development Fee Owner 2. Cash Flow (LP or LLC) 3. Deprec. w/ Basis Adj. Fee Ownership 1. HTC Property Lease End User 2. Cash Flow Lease 3. Deprec. w/ Basis Adj. End User

Master Lease/Credit Pass-Through Lessee Claims Credit Developer Development Fee GP/Manager Owner/Lessor (Affiliate of GP/Manager)

Master Lease/Credit Pass-Through Lessee Claims Credit Developer Development Fee GP/Manager Owner/Lessor (Affiliate of GP/Manager) Investor Master Lease Funds 0. 1% 99. 9% Tax Credits Master Lessee (LP or LLC) Property Lease End User

Master Lease/Credit Pass-Through Lessee Claims Credit Development Fee 3. Depreciation Owner/Lessor Developer (Affiliate of

Master Lease/Credit Pass-Through Lessee Claims Credit Development Fee 3. Depreciation Owner/Lessor Developer (Affiliate of GP/Manager) Funds 1. HTC GP/Manager HTC Investor Master Lease 99. 9% Tax Credits 0. 1% Master Lessee (LP or LLC) 2. Cash Flow 1. HTC/Imputed Inc. 3. Book Inc. -HTC Equity • Equity in Owner/Lessor • Loan to Owner/Lessor • Beware FIN 46 Property Lease End User Open Issues: 4. HTC Basis Adj. ?