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In January, the IRS issued Notice 2021-12 granting relief for various LIHTC requirements. Among the relief provided, the notice extended the deadline for a LIHTC site to meet its first-year occupancy obligations from Dec. 31, 2020, to June 31, 2021, for sites operating on a calendar-year basis. On March 16, the IRS issued Notice 2021-17 clarifying how increases in qualified occupancy six months after year-end affect the ability to claim LIHTCs. We’ll go over what effect the IRS’s recent clarification has on a site’s first-year requirements.
