Tuesday, December 11, 2012

Fee Changes for Historic Tax Credit Application

On November 30, 2012, the National Park Service announced changes to the fees for Part 2 and 3 of the Historic Preservation Certification Application. Part 2 and 3 respectively refer to the Description of Rehabilitation and Request for Certification of Completed Work portions of the application. The changes go into effect on December 31st, 2012.

Outline of fee changes as listed on NPS Website
Though the most dramatic fee increases occur for projects over $2 million in cost, the process does become slightly more complicated overall.  No fee will be collected for projects costing under $80,000,  and for projects that cost between $80,000 and $3,849,999, the fee will be $845 plus .15% of rehabilitation costs over $80,000. For instance, on a project with $1,080,000 worth of Qualified Rehabilitation Expenditures (QREs), the total fee to process Part 2s and 3s will be $2,345. Lastly, for all projects costing $3,850,000 or more, the fee will be a flat $6,500. 

One important change however is the assessment of the fee. Under the original process (and for any projects who submit their Part 2s prior to December 31st of this year), only $250 of the total fee was billed upon receipt of the Part 2, with the rest being paid upon submission of the Part 3. 

Under the new changes, half of the total fee will be billed upon submission of the Part 2, with the other half coming upon the submission of the Part 3. Thus for the hypothetical $1,080,000 million project listed above, the National Park Service would initially bill $1,172.50 out of the total $2,345 fee upon receipt of the Part 2. Important to note is that for projects whose Part 2s are denied by the National Park Service, the fee will not be refunded, nor will it be credited if a new Part 2 is submitted for the project.

If you have any questions concerning the new Part 2 and 3 fees, feel free to call Preservation Studios at 716-725-6410. 

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