Q & A | Is the Compliance Period for a Buildings or a Project?
Jan 11, 2023Question from a Blog Reader
"We are a state LIHTC monitor and we have a project that is treating each BIN as part of one multiple-building project. Most BINs are going to start credits this year, but for some BINs they elected to defer credits to next year. Do we look at each BIN individually regarding the end of the credit, compliance, and extended use periods, or do we apply "the most restrictive" (latest date) to determine the end of each period for the entire project?
Answer
Summary: The credit, compliance, and extended use periods all start with the first year credits are claimed for a BUILDING. Therefore, the periods are all specific to each BIN.
In the project that the reader describes, the periods for buildings that claim credits starting this year will end in one year, and the buildings that start next year will end one year later than the others.
Bonus: for a quick tutorial on determining the end of the credit, compliance, and extended use periods for each building, see the below example.
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There is a very good chance that the topic of this post is covered in an online on-demand course at Costello University.
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