"Year 15" is a reference to the way Section 42 of the Internal Revenue Code - Low-income housing credit - works. Lately holders of the investor interest in low-income housing projects have been resisting NFP sponsors trying to exercise ROFRs. Revenue Ruling 79-300 held that a low income housing project under Section 236 of the National Housing Act was not subject to Section 183 limitations. Recent CoverageA Primer on Federal Affordable Housing & Community Development Programs by the National Low Income Housing Coalition includes a discussion of the aggregator problem in Section 5-25 page 243. On the Tax Policy Center's Briefing Book - What is the Low-Income Housing Tax Credit and how does it work?

Source: Forbes February 16, 2021 18:12 UTC