On June 25, 2020 the California Tax Credit Allocation Committee issued a new memo providing additional guidance on the Average Income Test Federal Election.  In May 2018, TCAC adopted regulations that allowed projects with an existing tax credit reservation to elect the Average Income Test and make changes to the application’s housing unit designations, increasing some to 80% AMI. Effectively this permitted projects under construction and some projects nearing completion at the time of the legislation enactment to increase their maximums from 60% AMI to 80% AMI. TCAC is now providing additional guidance, consistent with IRS direction, that to be considered a 100% LIHTC project (not mixed income), all buildings in these projects must have a first year credit no earlier than 2018.