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Q My company manages a tax credit site with three buildings. Must we always apply the tax credit program’s requirements separately to each building, rather than to the site as a whole?
A No. In many cases, you apply the tax credit program’s requirements separately to each building. But there are two possible exceptions to this rule. If your tax credit site has more than one building, it’s important to know about these exceptions.
Q My company has used Section 4350.3 of the HUD Handbook to calculate household income at the Section 8 sites we manage. We’re about to start managing our first tax credit sites. Should we also use the Handbook to calculate household income at these sites?
Businesses seeking to recover coronavirus-related losses under their business interruption and property insurance policies have had difficulty in doing so because of questions as to whether their policies cover such losses. How those coverage questions will be resolved remains an open question, and a large number of lawsuits on COVID-19 coverage issues are already pending. Reports indicate that insurers are issuing blanket denials for such claims, but businesses should nonetheless file claims in order to satisfy the notice requirements, which secures a right to appeal.
Q We need to repaint some of the low-income units at our tax credit site. To accomplish this, we must temporarily displace residents—that is, have residents move out of their units—for a few days. Will the owner of our site stay entitled to claim credits for these units while their residents are displaced?
QMy management company will let a qualified applicant with no credit history sign a lease if she can find a guarantor. One applicant told us that if we rent a low-income unit to him, his guarantor will pay the rent for two months. If we accept the applicant, should we count these rent payments as part of his household’s income?
Q Our site is a project-based Section 8 site with LIHTC units. We recently found out that one of our residents who has lived at the site since 2007 got married in 2014 and never reported it. We know her husband doesn’t live in the unit because he’s a registered sex offender and he isn’t permitted on our property. Should the resident still have reported that she had gotten married and his income? She has never worked; she gets food stamps and cash assistance.
Q My company has just started managing our first tax credit site. Some of our applicants aren’t U.S. citizens. We’ve previously managed Section 8 sites and have had to reject applicants because they were noncitizens without proper documentation. Is there any citizenship requirement for tax credit sites?
Q The October issue of the Insider stated that foster children are not counted when determining household eligibility. (See “How to Calculate Correct Income for Adults and Dependents.”) Is this correct in light of the most recent change to HUD Handbook 4350.3, and how do we account for income from foster children/adults?
Q As I understand it, there’s an exception to the student rule for a single parent. At what age is the child no longer considered a child or a full-time student for the purposes of this exception?
A For the LIHTC program, a household cannot be comprised of all full-time students (kindergarten through 12th grade and institutions of higher education) unless they meet one of the following exceptions:
QThe October issue of the Insider stated that a full-time student household doesn’t violate the student rule if “the household consists of a single parent with a dependent child (or children), and neither the parent nor the child (or children) is being claimed as a dependent by anyone else.” (See “Use Lease Clause When Households Violate Student Rule Mid-Lease.”) In a situat
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