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DeKuiper, Elphick, Weinstein - Incorporating New IRS and CDFI … · 2016-07-20 ·...
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Incorporating New IRS and CDFI Fund Regulations into NMTC Structures
Transcript of DeKuiper, Elphick, Weinstein - Incorporating New IRS and CDFI … · 2016-07-20 ·...
Incorporating New IRS and CDFI Fund Regulations into NMTC Structures
InvestmentFund
CDE
Allocatee
Leverage Lender
Equity contribution$3,000,000
100% interest
Non-RecourseLeverage Loan
$7,000,000
QEI$10,000,000
99.99% interest
1% interest
99% interest
Reimbursement of Purchase of Land & Pre-Closing Costs (incurred less than
24 months from closing)$4,034,000
Development Fees$66,000
QALICB
QLICI$9,600,000
Individual
Investor
Equity contribution$1,000
.01% interest
Leverage Loan Original Sources3rd party long-term loan $2,000,000
Investor affiliate short-term bridge loan 4,100,000Leverage Lender equity 900,000
$7,000,000
Repayment ofInvestor affiliate loan
after closing$4,100,000
Other UsesPost-closing construction $4,066,000
Development Fees $ 594,000Reasonable working capital $ 400,000
Reserves $ 440,000
InvestmentFund
CDE
Allocatee
Leverage Lender
Equity contribution$3,000,000
100% interest
Non-RecourseLeverage Loan
$7,000,000
QEI$10,000,000
99.99% interest
1% interest
99% interest
Reimbursement of Purchase of Land (incurred more than 24 months from closing)
$1,500,000Reimbursement of Pre-Closing Costs (incurred less than 24 months
from closing)$2,600,000
QALICB
QLICI$9,600,000
Individual
Developer Fee$660,000
Developer(Related
Party)
Investor
Equity contribution$1,000
.01% interest
Leverage Loan Original Sources3rd party long-term loan $3,500,000
Investor affiliate short-term bridge loan 2,600,000Leverage Lender equity 900,000
$7,000,000
Repayment ofInvestor affiliate loan
after closing$2,600,000
Other UsesPost-closing construction $4,000,000
Reasonable working capital $ 400,000Reserves $ 440,000
Investment Fund
CDE
Allocatee
QALICB
Affiliate
Equity contribution$3,000,000
100% interest
Non-RecourseLeverage Loan
$7,000,000
QEI$10,000,000
99.99% interest
1% interest 99% interest
Reimbursement of Purchase of Land & Pre-Closing Costs
$4,100,000 QALICB
QLICI$9,600,000
Individual
Developer Fee$660,000
Developer(Related
Party)
Investor
Equity contribution$1,000
.01% interest
Other UsesPost-closing construction $4,000,000
Reasonable working capital $ 400,000Reserves $ 440,000
Leverage
Lender
Cumulative Annual Operating Cash Flow
Distributions$10,000,000
JuniorLeverage Loan Advances
During Compliance Period$7,000,000
Principal Repayments from Junior Leverage Loan
Advances$7,000,000
Arrow Key
Cash Flows at QLICI Closing
Cash Flows During the Compliance Period
Contact Information:
Kristin DeKuiper, Holland & Knight• [email protected]
Brad Elphick, Novogradac& Company• [email protected]
Ira Weinstein, Cohn Reznick• [email protected]
