Has anyone here gone through the full state Historic Rehabilitation Tax Credit process all the way through final voucher issuance?
Quick background: I'm in the Northeast. Completed a rehab on a certified historic commercial mixed-use building, all qualified rehab expenditures incurred and paid by me, preliminary certification and credit reservation in hand, submitting the final certification of completed rehabilitation today. Timing just worked out such that I'm also closing on a sale of the property before the voucher has been issued. Buyer needs to close asap. The credit doesn't make or break the deal, but I did the work and spent the money so I'd like to get it.
My question is procedural: at any point between submission of the final certification and issuance of the tax credit voucher, does the state historic preservation office or the state revenue agency actually pull a deed search or verify current ownership against the land records? Or do they rely entirely on the applicant's attestation and the project file?
I've read the program guidelines and the voucher request instructions — I know the voucher is issued to the "owner of record" — but I'm trying to understand whether this is a formality based on what you self-report, or whether there's an active verification step where they check who currently holds title. I was the owner during the spend and construction and would hate to see this technicality disqualify me from the credit.
Curious if anyone has been through a situation where ownership changed between the final certification submission and voucher issuance, and whether the agency flagged it or just processed based on the project file.
For federal surely you know you have to hold for 5 years - for state totally dependent on their rules so no idea how to answer just talk to someone at novoco with experience in your specific state. Personally I'd be surprised if you can sell before everything is finalized but that's just my gut.
It's really going to depend on the state. It's highly unusual to sell an HTC rehab shortly after completion, even if there are no federal credits and no state compliance period that could cause a recapture, so definitely a grey area. But generally speaking, it's very unlikely they'll perform an active check. Though you are still playing a game of audit roulette.
Thanks both — helpful perspectives.
In this state the credit is transferable, but the voucher is issued to whoever is the owner of record at the time of issuance, not necessarily the party who incurred the QREs. Since I’m selling before the voucher comes out, my options as I see it realistically are:
What I’m trying to understand is whether anyone has actually seen a state HTC office run a title check during that gap, or whether they simply process based on the submitted file
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