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Syndication Leasing Structures

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 Credits Internal Revenue Code Section 47. Tenants. Single Entity Structure. Tax Credit Investor LLC.

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Syndication Leasing Structures

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  1. Syndication Leasing Structures How Tax Credits Become Capital: When and How to Syndicate Panel USING HISTORIC TAX CREDITS IN NEW YORK June 24, 2009

  2. The Rehabilitation Tax Credits Internal Revenue Code Section 47

  3. Tenants Single Entity Structure Tax Credit Investor LLC Tax Credit Investor Managing Member (Developer Affiliate) HistoricTax CreditEquity 99.99% Credits, Profits & Losses and Cash Flow .01% Credits, Profits & Losses, Fees andCash Flow DeveloperEquity Tax Credit, LLC (Property Owner) Developer Dev.Fee DebtServicePayments RentalPayments LoanProceeds Construction/Perm Lender

  4. Sub-Tenants/End Users Master Lease/Credit Pass-Through Structure Tax Credit Investor LLC Managing Member (Developer Affiliate) .01% Credits, Profits & Losses, Fees andCash Flow DeveloperEquity >50% Profits & Losses, Fees and Cash Flow HistoricTax CreditEquity 99.99% Credits, Profits & Losses, and Cash Flow Landlord, LLC (Property Owner/Lessor) Master Tenant, LLC (Master Tenant) Pass-through of Historic Tax Credits & Share of Residual Lease Payment &Equity Investment <50% of Landlord Profits & Losses DebtServicePayments RentalPayments LoanProceeds Construction/Perm Lender

  5. Thank You Andrew Potts, Esq. 401 9th Street, NWSuite 900Washington, DC 20004 202.585.8337202.585.8080 (Fax) apotts@nixonpeabody.com

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