Tax Credit Syndication
Tax Credits
Low-Income Housing Tax Credits. Miles & Stockbridge lawyers have represented tax credit investors, syndicators and developers in LIHTC transactions throughout the country. As counsel for tax credit investors, we structure, document and negotiate the equity documents, as well as perform the necessary legal due diligence, including tax analysis, so that the equity investment is made in accordance with the investor’s requirements and applicable laws.
Historic Rehabilitation Tax Credits. Miles & Stockbridge attorneys pioneered the development of the master lease pass-through structure that has been adopted as the industry standard. When that structure was argued in the Historic Boardwalk case, a member of the Miles & Stockbridge team helped negotiate the terms of Revenue Procedure 2014-12 with the IRS and the U.S. Department of the Treasury. This matter serves as the primary guidance for closing historic rehabilitation and solar energy transactions.
Renewable Energy Credits. Miles & Stockbridge attorneys have been active in representing clients with respect to tax credit aspects of renewable energy transactions, with an emphasis on solar energy investments. These renewable energy transactions may be undertaken in conjunction with other federal income tax credits and can significantly enhance the yields received by the investor with respect to the combined transaction. Investment in projects located in Opportunity Zones can also substantially increase the yield. John Dalton is a frequent speaker at national Renewable Energy conferences.
New Markets Tax Credits. Our team at Miles & Stockbridge brought our transactional finance expertise to a number of projects in multiple states involving NMTC alone and NMTC twinned with other incentives including HTC and Opportunity Zones. Both individually and in partnership with other law firms, we have structured, documented and closed complex tax credit transactions involving multiple public and private financing sources and complicated structuring issues. John Dalton and other members of the group have spoken at NMTC conferences across the country.
