This allowed for qualified rehabilitation expenditures incurred in connection with the “certified rehabilitation” of a “certified historic structure” pursuant to the Section 47 of the Internal Revenue Code of 1986.
The firm prepared documents to effect aspects of the transaction. The firm negotiated the UEZ loan with the owner, the guaranty of gap financing with the senior lender, the subordination, non-disturbance and attornment agreement among the borrower, the historic tax credit pass-through lessee and BCDC, and the subordination and intercreditor agreement with the senior lender.