Federal Historic Tax Credit
What is It?
A 20% Federal income tax credit on the qualified amount of private investment spent on certified rehabilitation of a National Register listed historic building. The National Park Service is the agency that administers the program at the federal level. DAHP also has an integral role in the application process.
The Federal Historic Tax Credit Program (a.k.a. Investment Tax Credits or Rehabilitation Tax Credits) is one of the most useful incentives for encouraging the preservation of the state's historic resources. Since 1977, over 300 projects in Washington totaling over $2 billion dollars have been completed using the Federal Historic Tax Credit Program. Applications have averaged approximately 12 per year, with total investment per year ranging from several million dollars to more than $500 million. The smallest project ever certified was $14,000, while the largest ever certified was over $500 million.
Nationwide, the Federal Historic Tax Credit Program has levereged $116 billion in private investment since the program's inception in 1976. Over 47,000 buildings have been rehabilitated, creating more than 2.7 million jobs. In FY 2021 alone, there were more than 600,000 housing units rehabilitated or created;185,525 of which are low-moderate income. See the FY 2021 Fiscal year report here.
If you'd like to know where all of the projects have been in the last 10 years, go to our online application, DAHP on a MAP and turn on the Tax Credit Project layer.
Which Projects Qualify?
A building and project must be certified by the National Park Service in order for the property owner to claim the tax credit. There are four threshold requirements for a project to be certified by the National Park Service:
- The building must be listed in the National Register of Historic Places, either individually or as a contributing property to a district. If you're unsure about the status of your building, visit our online database of historic properties (WISAARD) to find out! You can also visit this web page to find out how a property can be listed in the National Register of Historic Places.
- The property must be income producing/comercially depreciable for at least five years following rehabilitation. This may include but not be limited to uses such as hotel, restaurant or bar, retail, office, rental residential, industrial, or agricultural. Owner-occupied residential properties do not qualify.
- The project must be substantial. This means the amount spent on “Qualified Rehabilitation Expenditures”* (QREs) must equal or be greater than the “Adjusted Basis” value** of the property. So the term "substantial" is relative to the building value, not the overall size of the project compared to other buildings or projects.
*Qualified Rehabilitation Expenditures (QREs) can be soft or hard project development costs, and not necessarily reserved for historic character defining features of a property.
**Adjusted Basis value is an IRS term to determine the “value” of a historic property using this basic formula:
A – B – C + D = adjusted basis, whereas:
A = purchase price of the property (building and land)
B = cost of land at time of purchase
C = depreciation taken for an income-producing property
D = cost of any capital improvements made since purchase
- The rehabilitation work must be done according to the Secretary of the Interior’s Standards for Rehabilitation (Standards). For further information on how to interpret the Standards, please contact our office, visit the NPS website, or hire a qualified architect or historic preservation consultant.
DAHP's role is to help you have a successful application. The most imporatant piece of advice we can give applicants, is to communicate with us very early in the planning phases of the project. This gives us the opportunity to inform you of any red flags that may cause an aplication to be denied. More than once an applicant has sent an application that does not meet the Standards, and, unfortunately, they are too far down the design path to make any changes. By coming to us early, we can get to these issues while it is still early enough to resolve them, if possible. The application process is often quite collaborative and we are happy to review and provide guidance on preliminary plans any time in the design process.
Applicants are not required to hire consultants to complete an application, but experienced preservation consultants can be helpful in navigaitng the process, especially for large, complex projects (DAHP does not endorse or keep a list of consultants). Depending on the project, you may need to complete either two or three parts of the application (forms are below). If the subject property contains more than one building, regardless of the age or National Register status of the buildings, the applicant is required to complete the Part 1 application. If the property is listed as contributing to a historic district, the applicant is required to complete a Part 1 application. The only case where a Part 1 is not required, is for a property that contains exactly one building that is already individually listed on the National Register of Historic Places.
Here is the basic process for a successful tax credit application:
- Call DAHP with preliminary ideas for a project. Get feedback and incorporate it into plans.
- Submit Part 1 application, if applicable. All application materials should be sent directly to DAHP. One hard copy, including cover page with original signature, and one digital copy are required for the Part 1 application. Mailing address is below. We also require the entire application in digital format. The hard copy is sent to NPS and the digital is for DAHP records. When NPS has reviewed the Part 1, they will send a notification letter of their decision via email. This usually takes about 30 days.
- Submit Part 2 application. Send two hard copies of the Part 2 application and one digital copy. One hard copy is for NPS, one is for DAHP staff to review. DAHP review can take up to 30 days, depending on workload and leave schedules, but it usually takes less than 2 weeks. NPS review can take 30 days. When NPS has reviewed the Part 2, they will send a notification letter of their decision via email. Part 2 application reviews often include requests for additional information or conditions for approval, so expect that there may be adjustments to the scope of work.
- Should any changes need to be made during construction, an amendment must be submitted. If a change is made that is not approved through and amendment, the applicant is at risk of having the project denied.
- When work is completed, submit a Part 3 application. The Part 3 basically includes "after" photos of the completed work. Please submit one hard copy (for NPS) and one digital copy.
Technical assistance and application information are available from the state Department of Archaeology and Historic Preservation. The office reviews all applications and makes comments and recommendations. Final review and approval is made by the National Park Service in its Washington, D.C. office. The application is three parts for most projects and the forms are available for download below.
When you click on the form links the PDF viewer might give you a message that it can't preview the file. Press the Download button and save it to your computer and it will work fine. Note for Apple users: You must right click (or double click, or hold Control and click, depending on your mouse/trackpad settings) and "Save As" or "Download As" on the link below rather than clicking on the link. Clicking on the link will tell you that you must update your Adobe Acrobat Reader.
Note for PC users: The application forms are fillable PDFs. Download and “Save As” under a new file name before filling out the form.
- Part 1 (Evaluation of Significance)
- Part 2 (Description of Rehabilitation)
- Amendment Form - use this form to get approval for changes or provide additional information not included in the original Part 2 submittal
- InDesign Photo template (requires Adobe InDesign) - Template that can be used for photo pages
- Part 3 (Request for Certification of Completed Work)
Hard copy applications should be mailed/FedEx to: DAHP, PO Box 48383, Olympia WA 98504
Digital versions should be emailed (or use a file transfer link) to email@example.com.
Below are some resources to help you through the application process. But always feel free to contact us directly if you have specific questions!
|1-1 National Register and the Tax Credit Program||1-2 Planning a Successful Tax Credit Application|
|2-1 Federal Historic Tax Credit Program Requirements||2-2 Storefronts, Windows & Rooftop Additions - Meeting the Standards|
This 2018 presentation includes information about tax credit investment structuring. Click the image to download the PDF file.
The historic tax credit program is frequently used to offset the cost of seismic upgrades to historic buildings. Seismic interventions can be fairly invasive, but there is usually a way to incorporate these changes into historic structures. There are six videos to this series, sponsored byt APT and DAHP, that include many case studies of successful seismic upgrades to historic buildings.
Property owners in Certified Local Government communities often take advantage of Special Valuation, a local property tax incentive. Contact your local historic preservation officer to find out if Special Valuation is available in your area.
The New Markets Tax Credit (NMTC) Program permits taxpayers to receive a credit against Federal income taxes for making qualified equity investments in designated Community Development Entities (CDEs). Substantially all of the qualified equity investment must in turn be used by the CDE to provide investments in low-income communities. The credit provided to the investor totals 39% of the cost of the investment and is claimed over a seven-year credit allowance period. In each of the first three years, the investor receives a credit equal to five percent of the total amount paid for the stock or capital interest at the time of purchase. For the final four years, the value of the credit is six percent annually. Investors may not redeem their investments in CDEs prior to the conclusion of the seven-year period.
Since its inception in 2000, NTCIC has provided nearly $2 billion in capital for more than 200 HTC, NMTC, ITC, and LIHTC investment transactions, representing more than $7 billion in total development costs. NTCIC is the historic tax credit industry’s leading advocate for improving and expanding the use of federal and state HTCs having organized and chaired the Historic Tax Credit Coalition since 2009. National Trust Community Investment Corporation (NTCIC) enables tax credit equity investments that support sustainable communities nationwide. NTCIC places qualified tax credits for federal and state historic (HTC), new markets (NMTC), solar (ITC) and low-income housing (LIHTC) projects.
Also a priduct of the NTCIC, the Irvin Henderson Main Street Revitalization Fund provides tax credit financing to support transformational historic rehabilitation projects specifically located in low-income Main Street communities.
C-PACER (Commercial Property Assessed Clean Energy and Resilience)
C-Pacer allows property owners to access financing for qualifying energy efficiency, renewable energy, water conservation, and resiliency improvements for their buildings. The financing stays with the property, rather than with the building owner. Programs like C-PACER have enabled financing for over 2,000 property owners in 24 states and the District of Columbia. PACE financing is a financing tool that enables building owners to pay for critical building improvements that make their properties more valuable by reducing operating expenses, improving the health of occupants, and strengthening long-term sustainability. PACE financing provides a way for local governments and private lenders to cooperate on loans secured by the property tax obligation, similar to a local improvement district. The debt does not appear as an obligation on the building owner’s balance sheet, and the repayment obligation stays with the property rather than the owner whenever the building is sold.
C-PACER Workshop Presentation Video presented by the Washington Trust for Historic Preservation
- Richard Martinez, RMartinez@kitsapbank.com
Senior Vice President and Director, Municipal & Specialty Banking, Kitsap Bank
- Banu Erdim, BErdim@kitsapbank.com
Sustainability and ESG Analyst, Kitsap Bank
- John MacLean, firstname.lastname@example.org
President, Energy Efficiency Finance Corporation