Whew!
We've been working really hard to present
the reasonably complicated
tax credit information
in an organized and understandable format
and
we think we might finally have something for you.
So,
here
goes...
For the purposes of our discussion here, there are
basically three
tax credit programs that the majority of property owners
might
take
advantage of:
Mini glossary of terms to review before
we get started:
- basis: what you paid for your property
- adjusted
basis: value of the building [minus] the land value [plus] improvements
[minus] depreciation
- income-producing: basically,
property that brings an income, i.e., residential or business rental
- Certified
Local District: a district created by local ordinance and certified
by the U.S. Department of Interior as substantially meeting National
Register criteria list
- National
Register District: a district that is listed in the National Register
of Historic Places list
- contributing
building: it might be easier to state what is NOT a contributing
building, but... Basically, when a district is created, a survey
is done to determine which buildings contribute to the architectural
significance of that district. Surveyors look at how many buildings
there are and the percentage of "architecturally significant" buildings
to other properties in order to determine if the district has merit
and then, which buildings qualify. In order to qualify, a building
typically has to be at least 50 years old and has to have been
constructed during the period of significance for the district.
It cannot [at least on the exterior], have been so significantly
altered that it has lost its historic integrity.
Photography
At the outset, let
us say that across the board, with any of these programs, we recommend
the applicant take
plenty of pictures PRIOR TO ANY WORK TAKING PLACE.
Photographic documentation must cover all significant architectural features on the interior and exterior, as well as at least two photos from opposing corners in each room. This
refers to both the “before” and the “after” pictures.
The photos must be 35mm prints and we suggest you get several
reprints. You'll need to submit two or three sets, depending
on what programs you're applying
for and that doesn't include copies for your records. Please
remember, digital photos
and color copies are not acceptable.
For more information, follow the details laid out on page
13 of the Missouri Department of Economic Development's 16-page
PDF.
Applications
Need we say it? Yes, we figure we must: Make absolutely sure, when
sending in your application that you keep copies of EVERYTHING:
the applications,
the drawings
and extra sets of pictures. You should be completely prepared
in case someone calls you with questions on your project or, if the
unthinkable
happens,
and your application gets lost.
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[NPA]
is
a state-run program operated by the Missouri Department of Economic
Development. This program, typically
known
as "The Lottery," is determined by census and
is available to property developers and owner-occupants.
For our purposes, the entire
city of St. Louis is considered a qualifying or distressed
community. This program
has a limited time frame in which
applications are accepted.
They usually
begin
accepting in August sometime and usually
close
it down in November.
Those that are accepted are generally notified by letter
early in the new year. Read
Missouri statute.
Within this program there are three ways one can
apply:
1) rehabilitation: eligible [not distressed] and qualifying [distressed] areas
2) substantial rehabilitation: [distressed]
3) new construction: eligible [not distressed]
and qualifying [distressed] areas
Use this chart to understand the appropriate tax benefits for
your property.

Non-profits are excluded from this program. A non-profit can form a for-profit entity
to qualify - consult a tax professional for more information.
More
NPA info
Download NPA guidelines from
the State of Missouri [PDF]
NPA
applications [Word and PDF versions available]
Determine
if your property is eligible click on “enter a street address” and
enter the property address. Write down the census tract number and block
group number and look
up the census info by county and click on “Senate Bill 20 Qualifying
Areas by County.” [PDF]
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Whether you apply for the State, Federal or both,
certain rules apply. These rules are dictated by the Secretary of the Interior’s
standards for the treatment of historic properties. link
Missouri State Program
To qualify:
• property must be individually listed on the National Register of Historic
Places
OR
• property must be in a Certified
Local District or National
Register District AND
needs to be a contributing building
AND
• you must spend at least 50% of the basis on improvements
If you are presently in an area that is being surveyed
to create a district, you may be eligible to apply retroactively AFTER
the district has been established if you follow the guidelines for
the Secretary
of the
Interior's
standards.
Those standards
are broadly
defined so as to include all buildings in the
U.S. To learn more about a "hypothetical" project, we recommend calling
a tax credit
consultant or one of the state reviewers.
[We say hypothetical here because no one will be able to give you an absolute
"yes"
or
"no" regarding the specifics of your project at an early planning stage. But
by consulting and asking questions, you should be able to get some feedback and
a general idea if your project could have concerns allowing some revisions at
a
stage
when
it's
still relatively easy to change things.]
If you are within an established district, it is possible to schedule a site
visit [consult a tax credit consultant as to the best timing for a visit], however
you should understand that due to budget constraints, these visits cannot be
guaranteed. See
sidebar
for
contact
information.
To apply: The application process is broken down
into three parts, Parts 1A & 1B
are normally submitted at the same time.
• Part 1A: Preliminary Application: this has applicant's information, preliminary
estimated costs and other basic project info
• Part 1B: Rehabilitation Information: with 2 copies of this form you'll
send:
-- 2 sets of “before” pictures
-- 2 copies of your existing floor plan
-- 2 copies of your proposed floor plan
• Part 2: Final Certification: submitted when the project
is complete. With 2 copies of this form, you'll send:
-- 2 copies of an alien certification form [signed in front of a notary]
-- 2 copies of MO HTC-E form OR a spreadsheet but the signature page from
MO HTC-E must accompany the spreadsheet
and must
be
notarized.
You
should be prepared to provide back-up documentation to justify costs, i.e., receipts,
invoices, cancelled checks or some other form of documentation of your eligible
expenses.* Expenses are eligible under the terms of the program and must be legitimately
tied to the project.
-- 2 copies of a sign off from local municipality certifying applicant has
no outstanding building violations
-- 2 sets of “after” pictures
Program benefits:
• You can claim 25% of your eligible expenses. As a general rule, these
type of items are allowable: architects fees, materials & labor costs, and
utilities & mortgage interest during the time
of construction. Items generally not covered are
things that are considered
not part of the building: fencing, carpet,
landscaping and appliances, to name a few.
• Credits are applied to your Missouri State Income Taxes and can be carried
back
three
years
and
forward
10
years
[counting the year you are in, that would be
a total of 14 years]
• You will not receive the credits until the project is complete
• Credits are transferable
• No application fee
*Another way to document expenses is to hire
a CPA or public accounting firm that does auditing, have them review
your project expenses and provide that review as your documentation. Renovations with a total project cost exceeding $250,000 are required to be independently audited by a professional.
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Federal
Historic Preservation Tax Credit Program
To qualify: This program is open to income-producing
properties
• rental property
• property used for your business
AND
• property must be individually listed on the National Register of Historic
Places
OR
• property must be in a Certified
Local District or National
Register District
AND needs to be a contributing building
AND
• you must spend 50% of the adjusted basis on improvements
If you are applying for this program, you must retain
ownership of the property for five years from the
date tax
credits are issued. Homeowners typically cannot take
advantage of this program unless they are owner/occupants
of a multi-family and use the other units as income producing.
In this case,
credits could be obtained on the
portion of the interior that's income producing and a pro-rated portion
of the allowable exterior
improvements
like roofing
and tuckpointing.
To apply: This application process
is also broken down into three parts, aptly named, Parts 1, 2 and 3.
• Part 1: Preliminary application [Evaluation
of Significance]: basically you give the address
of the property, a description of the building's exterior and a
statement of its significance, and ask that they
certify
that it
is in a qualifying
district
and that the property
contributes to that district.
• Part 2: Rehabilitation information Historic
Preservation Certification Application. With 2 copies of your
application and a
$250.00 preliminary application fee [consider this a down payment
of the total fee], you'll also supply:
-- 2 sets of “before” pictures
-- 2 copies of the existing floor plan
-- 2 copies of the proposed floor plan
-- 2 copies of survey maps [available from
the Landmarks Association or from the Department of Natural Resources in Jefferson
City, see sidebar]
-- 2 copies of Whipple or Sanborn fire insurance maps [housed
at
Missouri History Library at 225 South Skinker, see sidebar]
• Part 3: Final Certification Information:
when your project is complete,
you will
submit:
-- 2 copies of Federal application Part 3
-- 3 sets of “after” pictures
-- the remaining portion of the application fee
The application fee is
based on the total eligible
project costs and the balance will be paid
at this time. You will have received a letter from the Federal
Tax
Credit
office prior to this time, stating the amount
of the remaining
portion.
And finally, if your project
exceeds $250,000, you must have an audit by a CPA.
This applies whether you're submitting an application for the State or
Federal programs.
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