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Technical Preservation Services Department Ohio Historic Preservation Office Ohio Historical Society 1982 Velma Avenue Columbus, Ohio 43211-2497 614/298-2000 2011

Historic Tax Credits Preparation & Application

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Judith Kitchen, of the Ohio State Historic Preservation Office, presented this presentation at the Heritage Ohio Historic Tax Credit Workshop in Springfield, Ohio on May 6, 2011. Event sponsored by PNC Bank.

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Page 1: Historic Tax Credits Preparation & Application

Technical Preservation Services

Department Ohio Historic Preservation Office

Ohio Historical Society

1982 Velma Avenue

Columbus, Ohio 43211-2497

614/298-20002011

Page 2: Historic Tax Credits Preparation & Application

The 20% Federal Historic Rehabilitation

Tax Credit:

The Basics

Page 3: Historic Tax Credits Preparation & Application

Federal Historic Rehabilitation Tax Credit

Federal Tax Credit for the Rehabilitation of Historic Buildings.

Income-Producing Use. Substantial Rehabilitation. Credit=20% of Qualified Rehabilitation Expenditures. Certified Historic Structure (Application). Certified Rehabilitation (Application).

Page 4: Historic Tax Credits Preparation & Application

Applying for the Federal Tax Credit

Preliminary meetings with Technical Preservation Services Department staff during the project planning stage, before any rehabilitation work is undertaken, are encouraged. We are here to assist you and we want your project to be successful. Reviewers are Mariangela Pfister, Rachel Krause, Scott McIntosh and Judith Kitchen.

Applications are submitted to the Ohio Historic Preservation Office for review and recommendations. Following state review, applications are submitted with state recommendations to the National Park Service in Washington, D.C. for final review and approval. The Internal Revenue Service administers the process of claiming the credit.

Page 5: Historic Tax Credits Preparation & Application

Federal Tax Credit Application Procedures

Applications are available online but must be submitted in paper form

Part 1—Evaluation of Significance—Determines Whether the Building Is or Is Likely to Be a Certified Historic Structure (Listed on the National Register of Historic Places).

Part 2—Description of Rehabilitation—Determines Whether the Proposed Rehabilitation Work Will Meet the Secretary of the Interior’s Standards for Rehabilitation.

Part 3—Request for Certification of Completed Work—Determines Whether the Completed Project Meets the Standards for Rehabilitation.

Page 6: Historic Tax Credits Preparation & Application

Part 1 Submission Requirements

• Descriptions of appearance and significance

• Labeled before-rehab (and current) photographs– Photo number, building

name and address– Brief description of view

being shown– Month and year photo was

taken

• Photo key• Historic district map with

building located• Two copies of everything

Page 7: Historic Tax Credits Preparation & Application

Part 1 Tips

• Carefully check the National Register status of the property. Don’t rely on assumptions.

• Each building (or functionally-related group of buildings), unless it is a single building listed individually on the National Register, requires a Part 1 application.

• If your building is not yet listed on the National Register, a draft nomination form must be submitted with the Part 1 application and the normal nomination and listing process should be started.

• Use National Register information to prepare the Part 1 narrative.• Submit the Part 1 application as early as possible.• When we receive your application (Part 1, Part 2, Part 3 or

Amendment) you will be sent an acknowledgement form. Make sure you receive this form and check it for accuracy. Also read the helpful notes at the bottom.

Page 8: Historic Tax Credits Preparation & Application

Part 2 Submission Requirements

• Narrative that clearly and completely describes before-rehab conditions and all intended work to the exterior, interior and site (photos and drawings are subordinate to the written narrative)

• Labeled “before” photographs of all areas of the building and site, keyed to the pre-rehab drawings

• Drawings (pre-rehab and after rehab)

• Other necessary information such as specifications, product data, window survey, sightline study, tenant guidelines

• Two copies of everything

Page 9: Historic Tax Credits Preparation & Application

Part 2 Tips

• The Standards for Rehabilitation do not require you to take certain actions. They come into play only when you are proposing to do something physically to the building.

• The Ohio Historic Preservation Office and National Park Service do not design projects. We may suggest solutions based on our experience, but we do so in reaction to the information we receive.

• Provide an introductory paragraph or two to summarize the project.• Submit everything at once and in the same package, if possible.

Our 30-day review period does not start until an application is complete.

• Complete and submit the federal fee payment form with the Part 2 to expedite National Park Service review.

• Submit an Amendment form for any changes to approved Part 2 work prior to doing the work.

Page 10: Historic Tax Credits Preparation & Application

Part 3 Submission Requirements

• Labeled “after” photographs of all areas shown in the Part 2 “before” photographs

• Evidence that all Part 2 Conditions were met

• Two copies of everything

Page 11: Historic Tax Credits Preparation & Application

Part 3 Tips

• Take the Part 3 photos from the same locations and number them the same as the Part 2 photos. That will make our review much easier.

• Submit additional photos to show that any conditions placed on the Part 2 approval were met.

• Submit an Amendment form with the Part 3 describing any work that was not undertaken.

Page 12: Historic Tax Credits Preparation & Application

The 25% Ohio Historic Preservation Tax Credit (OHPTC):

The Basics

Page 13: Historic Tax Credits Preparation & Application

Ohio Historic Preservation Tax Credit

State Tax Credit for the Rehabilitation of Historic Buildings. Administered by the Ohio Department of Development, with

Assistance from the Ohio Historic Preservation Office (OHPO) of the Ohio Historical Society and the Ohio Department of Taxation.

Credit=25% of Qualified Rehabilitation Expenditures, up to $5 million.

Competitively Awarded Based on Potential Economic Impact and Regional Distributive Balance (Application).

Historic Building Requirement (Application). Preliminary certifications are not permitted, but buildings designated by Certified Local Governments qualify.

Approved Rehabilitation Work (Application). For combined federal/state tax credit projects, the federal Part 2 data will automatically apply to the OHPTC project, so no separate rehabilitation description is required. Work on OHPTC projects cannot start prior to approval recommendation from OHPO.

Page 14: Historic Tax Credits Preparation & Application

Applying for OHPTC

Preliminary meetings are encouraged. We are here to assist you and we want your project to be successful.

Applications are submitted within the established application periods or Rounds to the Ohio Department of Development, which sends a copy to the Ohio Historic Preservation Office for determinations of historic building status and whether the rehabilitation work meets the Secretary of the Interior’s Standards for Rehabilitation.

Program status, applications, program policies and the

scoring system are available online.

Page 15: Historic Tax Credits Preparation & Application

The Secretary of the Interior’s

Standards for Rehabilitation

Helpful guidance for the successful rehabilitation of historic buildings

Page 16: Historic Tax Credits Preparation & Application

Rehabilitation:

Returning a property to a state of utility through repair or alteration, making possible an efficient

contemporary use, while preserving features significant to its history, architecture and culture.

Page 17: Historic Tax Credits Preparation & Application

Standards for Rehabilitation

The Standards for Rehabilitation are ten common-sense principles emphasizing the preservation of historic

character, repair rather than replacement and compatibility of alterations.

They apply to all types of historic buildings.

They pertain to exterior and interior features and spaces.

Page 18: Historic Tax Credits Preparation & Application

Historic Character

Environment

Size

Scale

Materials

Craftsmanship Details

Spaces

Shape

Site

Structure

Page 19: Historic Tax Credits Preparation & Application

Standard 1 - Find a compatible use.

Page 20: Historic Tax Credits Preparation & Application

Standard 2 - Preserve historic character.

Page 21: Historic Tax Credits Preparation & Application

Standard 3 - Don’t create a false sense of history.

Page 22: Historic Tax Credits Preparation & Application

Standard 4 - Preserve additions that have gained significance.

Page 23: Historic Tax Credits Preparation & Application

Standard 5 - Preserve distinctive features.

Page 24: Historic Tax Credits Preparation & Application

Standard 6 - Repair rather than replace. Match closely if repair is not possible.

Page 25: Historic Tax Credits Preparation & Application

Standard 7 - Do not cause damage to historic building materials.

Page 26: Historic Tax Credits Preparation & Application

Standard 8 - Protect significant archeological resources.

Page 27: Historic Tax Credits Preparation & Application

Standard 9 - Ensure that additions are compatible.

Page 28: Historic Tax Credits Preparation & Application

Standard 10 - Ensure that additions are reversible.

Page 29: Historic Tax Credits Preparation & Application

Making A Good Program Better/ Planning Successful Rehabilitation Projects,

the two goals of which are:

Making the requirements of the federal historic tax credit program clearer

andMaking the interpretation of the Secretary of the

Interior’s Standards for Rehabilitation more understandable.

In addition to Preservation Briefs and the Guidelines for Rehabilitating Historic Buildings, the most up-to-date information on the federal historic rehabilitation tax

credit program and applying the Standards for Rehabilitation is provided by

Page 30: Historic Tax Credits Preparation & Application

Ohio Historic Preservation OfficeOhio Historical Society