As most of you know, the Consolidated Appropriations Act 2018, signed into law in March 2018, permanently established a third minimum occupancy set-aside for LIHTC projects, commonly referred to as “Income Averaging” (IA).

The Authority has published an Income Averaging Policy that describes IA for owners developing LIHTC properties and provides guidance and requirements for implementation. Developers interested in selecting IA should review this policy fully and are encouraged to reach out to Authority staff to discuss IA.

Please note that the IRS has not yet issued guidance regarding implementation of and compliance with Income Averaging. It is anticipated that the IRS will issue guidance within the next six months, which may result in changes to this policy.

You can find the IA policy on the Authority’s website at https://www.nhhfa.org/low-income-housing-tax-credits.

If you have any questions, please contact Natasha Dube, Program Manager-LIHTC at 603-310-9281 or for compliance questions, contact Melanie Toscano, Portfolio Manager at 603-310-9265.

Sincerely,

Natasha Dube & Melanie Toscano