You may have taken NCHM’s Tax Credit Specialist (TCS) course and earned your certification with pride. but are there aspects of the housing credit program that still confuse you? Trying to decipher the LIHTC program can be a daunting task, but it’s one that NCHM is here to help you with.
We have found that digging into the program basics can often reveal valuable information needed to keep LIHTC properties in compliance. Here are a few tips:
In-depth reviews of IRS Forms 8609 and 8823 can be invaluable to the manager of a LIHTC site by clarifying compliance expectations. One of the most revealing pieces of information found in the 8609 is how the owner answered Question 8b under Part II of the form, which asks “Are you treating this building as part of a multiple-building project?” Known as the multiple-building election, there are numerous points of program compliance that depend on whether the owner answered “yes” or “no.” Do you know the answer to this question for your tax credit property?
It is always good for management to be familiar with IRS Form 8823 even if they have not had one (or more!) filed with the IRS for noncompliance at their site. Using this form is how the State Housing Agencies communicate their compliance monitoring findings to the IRS. The form itself details what they will be reviewing. For an even more comprehensive understanding, we recommend reading the IRS’s Guide to Completing Form 8823 – a vital resource for anyone involved in managing housing credit properties. If your property has ever had 8823s filed by the state agency, then researching the compliance solutions found in the 8823 Guide should go a long way toward avoiding the same mistakes.
The various layers of obligation placed upon management by state housing agencies, owners/investors, and the industry as a whole represent another set of challenges for managers of LIHTC sites. Peeling away these layers to understand which requirements originate from the Section 42 regulations and which ones come from other sources will help further management’s understanding of the program — which may be implemented differently in different parts of the country. Are you familiar with your state agency’s compliance requirements that go above and beyond those mandated by Section 42?
All of these concerns underscore the complexity of LIHTC and the need for management to know more than the basic program compliance requirements. To meet this demand, NCHM has developed the next generation of LIHTC training: TCS Advanced (TCSA). Offered as an online program, TCSA debuts December 8-11, 2015. The program will consist of three days of webinar-based instruction, followed by a fourth day of review. The class concludes with an online examination.
Day One will decipher some of the issues summarized in this article, and will include a homework assignment where participants will be asked to do some property sleuthing at their own sites.
If you feel ready to expand your LIHTC knowledge by learning more and discovering the specific connections between training and managing your property, consider registering for this exciting addition to NCHM’s ever-expanding compliance curriculum. More information will be available soon.