In a recent alert, the accounting firm Novogradac & Company has summarized two important IRS Private Letter Rulings impacting the New Markets Tax Credit Ruling:
“The Internal Revenue Service (IRS) last week released two private letter rulings (PLRs) that discuss the eligibility of a six-month cure for failure to meet the substantially-all requirement within the initial 12 months as required by the new markets tax credit (NMTC) program. The IRS states in PLR 201004008 and PLR 201004021 that the six-month cure period is not automatically tacked on to the 12-month period; instead it begins when a community development entity (CDE) becomes aware (or reasonably should have become aware) of the failure to meet the substantially-all requirement.”
