Avoiding Historic Tax Credit Recapture using Post-Certification Amendments

The National Park Service (NPS) historic tax credit (HTC) review process is often referred to as the 1-2-3 process, which makes one think that securing certification for a historic preservation rehabilitation project is easy as 1, 2, 3. First there’s a Part 1–Evaluation of Significance, followed by a Part 2–Description of Rehabilitation, and finished off with a Part 3–Request for Certification of Completed Work. However, there’s one part that is often overlooked, the five-year recapture and compliance periods.