Federal & State Tax Incentives
Our attorneys have represented clients in transactions that involve
various federal and state tax credits, including new markets tax credits,
historic rehabilitation tax credits, certified capital company tax credits, low
income housing tax credits, and motion picture tax credits. These credits can
play an important role in the financing and development of projects. Our
attorneys bring a multidisciplinary perspective to these transactions, derived
from training in business, finance, real estate, securities, and tax law.
New Markets Tax Credit Transactions
Jones Walker attorneys have experience structuring transactions
involving federal and state new markets tax credits. Our attorneys have
represented all parties that commonly participate in new markets tax credits
transactions. We have represented leverage lenders, community development
entities (CDEs) and their sponsors, and qualified active low income community
business (QALICB). We also have experience applying for, receiving, and
monetizing Louisiana state new markets tax credits. We are familiar with
structuring of leveraged loans, qualified equity investments (QEIs) and
qualified low income community investments (QLICIs), with QALICB compliance and
with preferred exit strategies. We have also been active with federal lobbying
efforts to expand the federal new markets tax credit program.
Historic Rehabilitation Tax Credit Transactions
Our attorneys have experience working on transactions involving federal
and state historic rehabilitation tax credits, including up front structuring,
exit strategies, and negotiations of operating/limited partnership agreements
with tax credits investors. We also have experience applying for, receiving,
and monetizing Louisiana state historic rehabilitation tax credits. We have
employed master lease arrangements where beneficial and are familiar with key
economic issues, such as the after-tax cost effectiveness of developer fees and
allocation of recapture risks. We have been active with federal lobbying
efforts to expand the federal historic rehabilitation tax credit program.
Certified Capital Company (CAPCO) Tax Credit Transactions
Our attorneys have experience structuring, negotiating and closing
investments in certified capital companies, including the documentation with
insurance company investors, credit enhancers, and trustees. Our attorneys have
closed 15 transactions under CAPCO programs in 6 different states and the
District of Columbia. We also draft, analyze, and revise proposed statutes
during legislative sessions; draft, analyze, and revise proposed regulations
during agency rulemaking; design compliance protocols; and issue closing
opinions on the qualification of qualified businesses.
Louisiana Motion Picture Investment Tax Credits
Our attorneys have experience with all aspects of the Louisiana motion
picture investor tax credits. We have represented lenders, production
companies, and tax credit purchasers in transactions under this program. We
also assist clients in monetizing these credits. Our projects involve tax
credits for motion picture production and development of infrastructure. We are
familiar with transactions that monetize tax credits, as well as pre and
post-production sales of credits generated.