Syndication Leasing Structures

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Syndication Leasing Structures

• How Tax Credits Become Capital When and How to
  Syndicate Panel
• USING HISTORIC TAX CREDITS IN NEW YORK
• June 24, 2009

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The Rehabilitation Tax Credits Internal Revenue
Code Section 47
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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
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Master Lease/Credit Pass-Through Structure
Tax Credit Investor LLC
Managing Member (Developer Affiliate)
.01 Credits, Profits Losses, Fees andCash Flow
DeveloperEquity
gt50 Profits Losses, Fees and Cash Flow
HistoricTax CreditEquity
99.99 Credits, Profits Losses, and Cash Flow
Master Tenant, LLC (Master Tenant)
Landlord, LLC (Property Owner/Lessor)
Pass-through of Historic Tax Credits Share of
Residual
Lease Payment Equity Investment lt50 of
Landlord Profits Losses
DebtServicePayments
RentalPayments
LoanProceeds
Construction/Perm Lender
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Thank You
Andrew Potts, Esq. 401 9th Street, NWSuite
900Washington, DC 20004 202.585.8337202.585.8080
(Fax) apotts_at_nixonpeabody.com