This is an abridged web edition of the Novogradac Journal of Tax Credits. Subscribe here to receive the complete magazine.

Despite remarkably successful track records — some decades-long — tax credit programs continue to come under attack by a handful of critics who suggest that cash grants might be more effective. To defend cost effective programs such as the low-income housing tax credit (LIHTC) and new markets tax credit (NMTC) against such attacks, Novogradac & Company has been commissioned to analyze the efficiency of the tax credits compared to that of comparable cash grants. We've also performed similar analysis of renewable energy tax credits (RETCs) and the historic tax credit (HTC).
As low-income housing tax credit (LIHTC) prices have continued to trend steadily upward since last year's rebound, the industry is focused on sustaining the market's momentum. But, for a variety of reasons, the long-awaited higher prices may be too much of a good thing, according to panelists at Novogradac & Company LLP's Affordable Housing Tax Credit Conference in San Francisco, Calif.
On August 16, the U.S. Department of Housing and Urban Development (HUD) issued Notice 2011-20 containing guidance for handling bed bug infestations. While technically limited to HUD-insured, HUD-held direct loan, Section 202, Project-Based Rental Assistance Contracts and properties with HUD use agreements, it is likely that the same standards will be applied to properties financed through other affordable housing programs, including the low-income housing tax credit (LIHTC).
Question 1: If a developer follows the safe-harbor guidelines for assets to be used in a renewable energy project, but ultimately that specific project cannot be completed, can the developer use the "safe-harbored" assets for another project and still qualify for a Section 1603 cash grant payment?
Yes, it's "déjà vu all over again!" Perhaps Yogi Berra would have had the same reaction to our new annual ritual of worrying about how to grandfather renewables projects for Section 1603 grants. While some are still hoping that the Section 1603 program will be extended another year, it seems that grandfathering is a serious concern this year, so I thought it would be a good idea to provide an update to what you should be thinking about with respect to getting a Section 1603 grant next year and beyond.
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