IRS Provides Short-Term Relief for Certain Deadlines

On April 10, the IRS issued Notice 2020-23, which postpones various deadlines between April 1 and July 15 to a new July 15, 2020, deadline. Here is a full list of April 1 – July 15 LIHTC deadlines extended by Notice 2020-23 to July 15, 2020:

• The 10 percent test requirement as referenced in Section 42(h)(1)(E) and (F).
• The 24-month period in which the requisite amount of rehabilitation expenditures has to be incurred as required in Section 42(e)(3)(A)(ii).
• The annual owner certification of compliance as required in regulation 1.42-5(c)(1).
• The annual tenant income certification requirement in regulation 1.42-5(c)(1)(iii).
• The requirement to notarize a binding agreement by the fifth day following the end of the month in which the binding agreement was made as referenced in regulation 1.42-8(a)(3)(v).
• The requirement to notarize a binding agreement by the fifth day following the end of the month in which the tax-exempt bonds are issued as referenced in regulation 1.42-8(b) (1)(vii).
• The 10-year rule for claiming credits on an existing building as required in Section 42(d)(2)(D)(i)(IV).
• The minimum set-aside requirement as referenced in Section 42(g)(3)(A).
• The requirement that a low-income housing commitment must be in effect as of the beginning of the year for a building to receive credit as referenced in Section 42(h)(6)(J).