IRS HTC Guidance

Regulations

Treasury Regulation Section 1.48-12
Internal Revenue Code and Treasury Regulations Regarding the Investment Tax Credit for Qualified Rehabilitation Expenditures

Internal Revenue Code Section 47
Internal Revenue Code Regarding the Rehabilitation Tax Credit

Federal Register Notices

Final Regulations: Rehabilitation Credit Allocated Over a 5-Year Period
Sep. 15, 2020

Proposed Regulations Concerning the Rehabilitation Credit, Including Rules to Coordinate the New 5-Year Credit Period
May 22, 2020

Income Inclusion When Lessee Treated as Having Acquired Investment Credit Property
July 19, 2019

Agency Information Collection Activities; Historic Preservation Certification Application
July 2, 2019

Centralized Partnership Audit Regime
June 14, 2017

Election Into the Partnership Audit Regime Under the Bipartisan Budget Act of 2015
August 5, 2016

Election Into the Partnership Audit Regime Under the Bipartisan Budget Act of 2015 (Proposed Rules)
August 5, 2016

Proposed Collection; Comment Request for Regulation Project
August 5, 2016

Final and Temporary Regulations: Income Inclusion When Lessee Treated as Having Acquired Investment Credit Property
July 21, 2016

Income Inclusion When Lessee Treated as Having Acquired Investment Credit Property
July 21, 2016

Private Letter Rulings

PLR 201418035
May 2, 2014
Rehabilitation of two properties under § 168(h)(1)(B) of the Internal Revenue Code

PLR 201412005
March 21, 2014
Extension of time to make the election under § 1.48-4 of the Income Tax Regulations for Year 1

PLR 201243003
October 26, 2012
Multiple Buildlings May be Treated as a Single Building Under §168(e)(2) and § 1250

PLR 201234020
August 24, 2012
Extension of time to make the election under § 1.48-4 of the Income Tax Regulations for Year 1

PLR 201228019
July 13, 2012
Extension of time to make the election under § 1.48-4 to treat Tenant as having purchased Property

PLR 201228016
July 13, 2012
Aggregation for purposes of the tax-exempt use property test

PLR 201228015
July 13, 2012
Aggregation for purposes of the tax-exempt use property test

PLR 201120010
May 20, 2011
Extension of time to make the election under § 1.48-4 to treat Tenant as having purchased Property

PLR 201119016
May 13, 2011
Extension of time to make the election under § 1.48-4 to treat Tenant as having purchased Building

PLR 201119006
May 13, 2011
Extension of time to make the election under § 1.48-4 to treat Tenant as having purchased Building

PLR 201103025
January 21, 2011
Section 168; Modified Accelerated Cost Recovery System (MACRS)

PLR 201048019
December 3, 2010
Extension of Time to File an Application for Certification of Historic Status

PLR 201045013
November 12, 2010
Carryback of Unused Rehabilitation Tax Credits under Section 38(c)(4)

PLR 201008020
February 26, 2010
Extension of Time to File an Application for Certification of Historic Status

PLR 200943001
October 23, 2009
Extension of Time to File an Application for Certification of Historic Status

PLR 200926022
June 26, 2009
50 Percent Exception to the Definition of Tax-Exempt Use Property

PLR 200841003
October 10, 2008
Tax-Exempt Use Property

PLR 200518016
May 6, 2005
Exterior Stair Attached to Historic District Property

PLR 200430027
July 23, 2004
Extension of Time for Making Certain Elections

PLR 200416003
April 16, 2004
Rehabilitation Credit - Certification of Historic Status

PLR 200408003
February 20, 2004
Extension of Time to File an Application for Certification of Historic Status

PLR 200048032
December 1, 2000
Ability to Take into Account Certain Expenditures Incurred with Respect to the Rehabilitation of Building

PLR 8943074
August 2, 1989
48(d) (Superceded by 50(d)) Income Not Accelerated If Leases Terminated

Revenue Procedures

Rev. Proc. 2014-12
January 2014
Safe Harbor for Partnership Allocations

Historic Tax Credit Coalition Summary of Rev. Proc. 2014-12
January 10, 2014

Rev. Proc. 95-27
January 1995
Safe Harbor for Certain Structural Modifications

Revenue Rulings

Rev. Rul. 89-90
Recapture Under Section 47 of the Code

Rev, Rul. 79-315
Gross Income Under Section 61

Notices

Notice 2020-58: IRS Extends Deadline to Meet Substantial Rehabilitation Test for Claiming Historic Tax Credit
July 30, 2020

Notice 2018-43: Public Comment Invited on Recommendations for 2018-2019 Priority Guidance Plan
April 27, 2018

Notice 2017-58
October 2, 2017
Extended Due Date under Notice 2017-10 for Participants Affected by Hurricanes Harvey, Irma, or Maria

Notice 2017-29
April 27, 2017
Syndicated Conservation Easement Transactions Identified in Notice 2017-10

Notice 2017-10
December 23, 2016
isting Notice--Syndicated Conservation Easement Transactions

Notice 2010-62
September 13, 2010
Interim Guidance under the Codification of the Economic Substance Doctrine and Related Provisions in the Health Care and Education Reconciliation Act of 2010

Chief Counsel Advice

AM 2021-001
March 8, 2021
Section 170(h)(4)(B)(i) and Installation of an Accessibility Ramp Required by the Americans With Disabilities Act

AM 2016-001
April 15, 2016
Nonrecourse Carve-Outs Do Not Cause Debt to fail to Qualify as Nonrecourse Debt

CCA 201641022
October 7, 2016
Form 3468 and Section 47 Rehabilitation Credits

CCA 201507020
February 23, 2015
Form 4255 and Section 47 Rehabilitation Credits

CCA 201505038
January 30, 2015
Income Inclusion Amount under Section 50(d)(5)

CCA 201334039
August 23, 2013
Valuing Conservation Easements under § 1.170A-14(h)(3) of the Income Tax Regulations

CCA 20125201F
December 28, 2012
Tax Years Through Analysis of Negligence Penalty and Reasonable Basis Under I.R.C. 6662 and Reasonable Cause and Good Faith Under I.R.C. 6664

CCA 20124002F
October 5, 2012
Rehabilitation Tax Credit Issue

CCA 201147024
November 25, 2011
Tax Treatment of Massachusetts State Tax Credits

CCA 200943034
October 23, 2009
Façade Easement Brief June 2009

CCA 200943033
October 23, 2009
Façade Easement Brief June 2009

CCA 200445046
November 5, 2004
Massachusetts Transferable Tax Credits

CCA 200238041
September 20, 2002
Colorado Conservation Easement Credit

CCA 200126005
June 29, 2001
Colorado Conservation Easement Credit