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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. Owner (LP or LLC). Development Fee. Developer. Fee Ownership. Property. Lease. Lease. End User. End User.
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Historic Preservation Tax CreditsThe Next Level: “Master Tenant” Syndication
Single Entity Structure GP/Manager Investor 99.9% Tax Credits 0.1% Management Fees, etc. Owner (LP or LLC) Development Fee Developer Fee Ownership Property Lease Lease End User End User
Single Entity Structure Cash Flow: 1. Fixed Fees 2. Gross Revenues GP/Manager HTC Investor 99.9% Tax Credits 0.1% Management Fees, etc. 1. HTC 2. Cash Flow 3. Deprec. w/ Basis Adj. Owner (LP or LLC) Development Fee Developer Fee Ownership Property 1. HTC 2. Cash Flow 3. Deprec. w/ Basis Adj. Lease Lease End User End User
Master Lease/Credit Pass-ThroughLessee Claims Credit Development Fee Developer Owner/Lessor (Affiliate of GP/Manager) GP/Manager Investor Master Lease Funds 0.1% 99.9% Tax Credits Master Lessee (LP or LLC) Property Lease Lease End User End User
Master Lease/Credit Pass-ThroughLessee Claims Credit Development Fee Developer Owner/Lessor (Affiliate of GP/Manager) 3. Depreciation HTC Investor Master Lease Funds 1. HTC GP/Manager 99.9% Tax Credits 1. HTC/Imputed Inc. 0.1% Master Lessee (LP or LLC) 3. Book Inc.-HTC Equity •Equity in Owner/Lessor • Loan to Owner/Lessor • Beware FIN 46 2. Cash Flow Property Open Issues: 4. HTC Basis Adj.? Lease Lease End User End User