Revenue Procedure 2014-12 – the Historic Boardwalk Safe Harbor

    View Authors January 2014
    The Internal Revenue Service issued Revenue Procedure 2014-12 establishing a Safe Harbor under which allocations by partnerships to partners of historic rehabilitation tax credits under Section 47 of the Internal Revenue Code of 1986, as amended will be respected. The Safe Harbor is in direct response to the adverse decision of the Historic Boardwalk case that brought investment in historic projects nearly to a halt, and was intended to provide investors with the necessary comfort to resume investments in historic rehabilitation tax credit transactions. This publication summarizes the Safe Harbor and provides suggestions for structuring an HTC transaction to satisfy the Safe Harbor.