Ozone benefit for a $10mm investment

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Presentation transcript:

Ozone benefit for a $10mm investment Original income tax basis - 0 - Additions to basis after seven year hold $1,500,000 Adjusted tax basis $1,500,000 Less: lower of deferred gain or 12/2026 FMV ($ 3,200,000) Taxable capital gain as of 12/31/2026 $1,700,000 Capital gains tax at 4/15/2027 at 21% tax rate $357,000* *Versus $2,100,000 at 4/15/19

“Typical” LIHTC project without Ozone benefit Opportunity Zone Fund Benefit Schedule for Investor 1 9% New Construction (City, ST) October 2018 - December 2037 Property Cash Needs Cash Used for Federal Investment Load AMF Reserves Gross Proceeds Federal Tax Credits Total Tax Deductions Capital (Gain) / Loss on Disposition Tax Benefits at 21.0% Net Benefits Cumulative Net Benefits 2018 1,603,400 334,042 5,000 1,942,442 - 24,040 5,048 (1,937,393) 2019 5,447,835 5,150 5,452,985 577,051 1,167,245 822,173 (4,630,812) (6,568,205) 2020 965,765 5,305 971,070 900,720 458,138 996,929 25,859 (6,542,346) 2021 5,464 466,246 998,632 993,168 (5,549,178) 2022 5,628 470,820 999,592 993,965 (4,555,213) 2023 5,796 480,675 1,001,662 995,865 (3,559,348) 2024 5,970 489,150 1,003,441 997,471 (2,561,877) 2025 6,149 498,434 1,005,391 999,242 (1,562,635) 2026 6,334 503,278 1,006,408 1,000,075 (562,561) 2027 6,524 509,657 1,007,748 1,001,224 438,664 2028 6,720 513,189 1,008,490 1,001,770 1,440,434 2029 6,921 323,669 515,830 431,993 425,072 1,865,506 2030 7,129 521,459 109,506 102,378 1,967,883 2031 7,343 529,054 111,101 103,759 2,071,642 2032 7,563 535,786 112,515 104,952 2,176,594 2033 7,790 543,314 114,096 106,306 2,282,900 2034 175,493 36,854 2,319,754 2035 2036 2037 8,017,000 100,784 8,451,826 9,007,200 8,226,317 10,771,580 Quarterly Effective IRR Quarterly Effective - After Tax: 5.10%

Same project with Ozone benefit Opportunity Zone Fund Benefit Schedule for Investor 1 with Opportunity Zone Incentives 9% New Construction (City, ST) October 2018 - December 2037 Property Cash Needs Cash Used for Federal Investment Load Allocable Investment AMF Reserves Gross Proceeds Capital Gains Tax Deferral Capital Gain Recognized Opportunity Zone Exemption Capital Gains Tax Federal Tax Credits Total Tax Deductions Capital (Gain) / Loss on Disposition Exempted Gain on Disposition Tax Benefits at 21.0% Net Benefits Cumulative Net Benefits 2018 1,603,400 334,042 1,937,442 5,000 1,942,442 406,863 - 24,040 5,048 (1,530,531) 2019 5,447,835 5,150 5,452,985 1,144,045 577,051 1,167,245 822,173 (3,486,767) (5,017,297) 2020 965,765 5,305 971,070 202,811 900,720 458,138 996,929 228,670 (4,788,627) 2021 5,464 466,246 998,632 993,168 (3,795,459) 2022 5,628 470,820 999,592 993,965 (2,801,495) 2023 5,796 480,675 1,001,662 995,865 (1,805,629) 2024 5,970 489,150 1,003,441 997,471 (808,158) 2025 6,149 498,434 1,005,391 999,242 191,084 2026 6,334 2,672,333 (1,252,656) (298,132) 503,278 1,006,408 701,942 893,026 2027 6,524 509,657 1,007,748 1,001,224 1,894,250 2028 6,720 513,189 1,008,490 1,001,770 2,896,020 2029 6,921 323,669 515,830 431,993 425,072 3,321,092 2030 7,129 521,459 109,506 102,378 3,423,470 2031 7,343 529,054 111,101 103,759 3,527,228 2032 7,563 535,786 112,515 104,952 3,632,181 2033 7,790 543,314 114,096 106,306 3,738,487 2034 175,493 36,854 3,775,340 2035 2036 2037 8,017,000 8,351,042 100,784 8,451,826 1,753,719 9,007,200 8,226,317 10,771,580 Quarterly Effective IRR Quarterly Effective - After Tax: 10.31%

Open Issues How should the Ozone benefit be split between investors and developers. If there is .10 in pricing spread between non-zone and ozone benefits, many developers will ask for .08 despite having done nothing to earn it and the risk that the state agencies will simply cut back on their LITC allocations State taxation – the ultimate benefit analysis of a LIHTC/Ozone investment needs to consider state taxation. The outcome can vary widely from a state that does not follow the current IRC to a state like Ohio which is considering adding a 10% state tax credit for Ohio projects Will we be able to stage capital installments to match completion benchmarks without running afoul of the so-called “90% test” IRS/Treasury are likely to add investment impact reporting requirements