Tax Credits: Opportunities to Improve Oversight of the Low-Income Housing Program

Published by the Government Accountability Office on 1997-04-23.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                        United States General Accounting Office

GAO                     Testimony
                        Before the Subcommittee on Oversight, Committee on
                        Ways and Means, House of Representatives

For Release on
Delivery Expected at
1:30 p.m., Wednesday
                        TAX CREDITS
April 23, 1997

                        Opportunities to Improve
                        Oversight of the
                        Low-Income Housing
                        Statement of James R. White, Associate Director, Tax
                        Policy & Adminstration Issues, General Government


Tax Credits: Opportunities to Improve
Oversight of the Low-Income Housing
                  Madam Chairman and Members of the Subcommittee,

                  We appreciate being here this afternoon to discuss our recently issued
                  report entitled Tax Credits: Opportunities to Improve Oversight of the
                  Low-Income Housing Program (GAO/GGD/RCED-97-55, March 28, 1997).
                  Currently, the tax credit is the largest federal program for funding the
                  development and rehabilitation of rental housing for low-income
                  households. Under this program, the states award tax credits that could
                  cost federal taxpayers as much as $3 billion per year.

                  Our report, which is addressed to you, Madam Chairman, and the
                  Chairman of the Ways and Means Committee, answers questions about the
                  characteristics of tax credit projects and their residents and the controls
                  the Internal Revenue Service (IRS) and the states have over the program.
                  More specifically, with respect to controls we were asked to assess IRS and
                  state controls for ensuring that (1) state priority housing needs are met;
                  (2) housing project costs, including tax credit costs, are reasonable; and
                  (3) states and project owners comply with program requirements.

                  In answering these questions, our report makes the following four main

              •   A substantial majority of the households served by the program had
                  incomes considered “very low” by the Department of Housing and Urban
                  Development and about three-fourths of all households benefited either
                  directly or indirectly from other types of housing assistance. We estimate
                  the average tax credit cost per-unit, in present value terms, to be about
              •   All the states had developed qualified allocation plans required by the
                  Internal Revenue Code to direct tax credit awards to priority housing
                  needs. Although the states met tax code requirements, we identified
                  several factors that could affect the housing actually delivered over time.
                  Some states reserve discretion for amending or bypassing the allocation
                  process. In addition, many tax credits that were initially allocated may not
                  have been used. Further, the long term economic viability of tax credit
                  projects as low-income housing has not been tested.
              •   All states had cost control procedures in place that were intended to help
                  ensure the reasonableness of project costs and tax credit awards.
                  However, some projects lacked complete cost and financial data and some
                  key data used in determining the basis for tax credit awards were not
                  independently verified.

                  Page 1                                                GAO/T-GGD/RCED-97-149
                      Tax Credits: Opportunities to Improve
                      Oversight of the Low-Income Housing

                  •   While states had established compliance monitoring programs consistent
                      with IRS regulations, the regulations did not provide adequate assurance
                      that states perform agreed upon monitoring reviews. Also, IRS needs
                      additional information to adequately monitor states’ tax credit allocations
                      and taxpayer compliance with credit requirements.

                      Before elaborating on these points I would like to describe our
                      methodology and provide some background about how the low income
                      housing tax credit program works and the responsibilities of the IRS and
                      states for administration and oversight of the program.

                      Our analysis of the low-income housing tax credit program is based
                      primarily on a survey of tax credit policies and procedures in 54 state tax
                      credit allocating agencies, a review of state files for 423 randomly selected
                      housing projects, and a survey of project managers for these projects. We
                      also reviewed IRS’ low-income housing tax credit procedures and

                      The low income housing tax credit program is a joint federal, state and
How the Program       private sector initiative. Figure 1 attached to this statement illustrates for a
Works                 simple case how tax credits help finance low-income housing
                      development. Under the program, a developer finances a low income
                      housing project in part using a private mortgage, with payments made out
                      of rental revenues, and in part using equity paid into the project from
                      investors who receive the credit. The greater the private financing, the
                      smaller the amount of tax credit needed.

                      The process of awarding tax credits to private investors begins with IRS
                      annually allocating tax credits to each state housing agency in an amount
                      equal to $1.25 per state resident. Developers proposing to build
                      low-income housing apply to the state agencies for credits. Winning
                      developers receive credits which they in turn offer, in effect sell, to private
                      investors, often organized into partnerships by syndicators, who use the
                      credits to offset taxes otherwise owed on their tax returns. In return for
                      the credits, the private investors provide equity financing for the projects.
                      This equity financing fills the gap between the development costs and the
                      non-tax credit financing. The equity paid into a project is less than the sum
                      of the tax credits. The difference provides the investors with a rate of
                      return over 10 years as well as compensation for housing project
                      evaluation and monitoring. A complication not shown in the figure is that
                      many projects also receive other housing subsidies.

                      Page 2                                                   GAO/T-GGD/RCED-97-149
                    Tax Credits: Opportunities to Improve
                    Oversight of the Low-Income Housing

                    About $300 million in new credits are made available nationally each year
                    for award to new housing projects. Assuming project owners remain
                    eligible, they would be entitled to take the $300 million in credits each year
                    for 10 years. Thus, if this occurred, in any one year, 10 years worth of
                    federal tax credits would be outstanding and the aggregate annual cost to
                    the federal government would be $3 billion.

                    The states and IRS share responsibility for administering the tax credit
                    program. Once projects have been placed in service, state agencies are
                    responsible for monitoring the projects for compliance with federal
                    requirements concerning household income and rents and project
                    habitability. Noncompliance with these requirements may result in IRS
                    recapturing or denying previously issued or used tax credits.

                    IRSis responsible for issuing regulations on state monitoring requirements,
                    ensuring that taxpayers take no more tax credits than they are entitled to
                    take, and ensuring that states allocate no more credits than they were
                    authorized to allocate. In implementing these responsibilities, IRS requires
                    annual reports from the states on the amount of tax credit allocations
                    made in total and amounts awarded to individual projects. IRS also requires
                    taxpayers to disclose tax credit information on their tax returns and
                    requires the states to report findings of project noncompliance.

                    We estimated, based on our random sample, that about 4,100 properties
Housing Delivered   with about 172,000 tax credit qualified units were placed in service in the
Under the Program   continental United States between 1992 and 1994. We also estimated that,
                    for these projects, the states annually awarded tax credits with a potential
                    value over their 10-year lifetime of about $2 billion (about $1.6 billion in
                    present value terms), or about $6.1 billion for the three years combined.

                    On the basis of information from our survey of property managers, we
                    estimated that the 1996 average annual income of households in units
                    qualifying for tax credits was about $13,300. The distribution of incomes is
                    shown in figure 2, which is attached to this statement. About three-fourths
                    of tax credit households met HUD’s definition of “very low income”—that
                    is, their incomes were below 50 percent of their area’s median income.
                    About 71 percent of the tax credit households, benefited directly or
                    indirectly from one or more types of housing assistance besides tax
                    credits. One type of housing assistance, direct rental assistance, enabled
                    the tax credit program to serve many households whose reported income
                    was well below the qualifying limits established by the program. Overall,

                    Page 3                                                  GAO/T-GGD/RCED-97-149
Tax Credits: Opportunities to Improve
Oversight of the Low-Income Housing

an estimated 39 percent of the households received direct rental
assistance. The average income for these households was about $7,900.

Tax credit households were small—about two-thirds were one or two
person households. About a quarter of the projects were developed
primarily to serve the elderly.

Tax credit properties were located throughout the country. The most
common type of property was a walk-up/garden-style apartment building
but properties ranged from row houses to elevator buildings. Most of the
projects were newly constructed.

The average monthly rent was about $450. For some tenants rental
payments were covered in part by other federal housing assistance.

We estimated that for the tax credit properties placed in service between
1992 and 1994, the states had annually awarded tax credits with a potential
value over 10 years of about $2 billion (about $1.6 billion in present value
terms). Thus, the taxpayer costs for the tax credits attributable to these
three years could be as high as $6.1 billion over the 10-year credit period.
We also estimated that the present value of the average tax credit cost per
unit would be about $27,310. As shown in figure 3, which is attached to
this statement, about 60 percent of the units had tax credit costs at or
below the estimated average and about 2 percent had tax credit costs of
$100,000 or more. The federal costs of the tax credits is a function of many
factors, including property development costs and the market price of the
tax credit.

Project development costs, including land and building acquisition outlays,
construction costs, builders’ profit, and financing costs, varied widely. We
estimate that the average cost of developing the units was about $60,000.
About two-thirds of these units cost less than or the same as the average
unit. As shown in figure 4, which is attached to this statement, the per-unit
costs of the properties varied widely. About 10 percent of the properties
cost less than $20,000, and about 10 percent cost more than
$100,000—including 3 percent whose costs exceeded $160,000 per unit.
Development costs may vary because of differences in the physical
characteristics of properties, broader community development needs, and
the extent to which tax credit allocating agencies use various controls to
limit costs.

Page 4                                                 GAO/T-GGD/RCED-97-149
                            Tax Credits: Opportunities to Improve
                            Oversight of the Low-Income Housing

                            All the states had developed qualified tax credit allocation plans required
State Controls for          by the Internal Revenue Code to direct tax credit awards to meet priority
Allocating Credits to       housing needs. The plans generally targeted the credit to the priority
Housing Needs Vary          housing needs identified by the states. Consistent with the latitude given
                            them in the Code, the states had defined and weighted the selection
                            criteria for awarding credits in different ways. Most states used some sort
                            of scoring system to rank project proposals. The states also used varying
                            amounts of data and analyses in assessing housing needs.

                            Although all states had adopted required allocation plans for meeting state
                            set housing priorities, we identified several factors that could affect the
                            housing actually delivered over time.

                        •   One factor involves the use of discretionary judgment. Nearly all of the
                            agencies reserved some discretion for amending or bypassing their
                            allocation process. We recognize that discretion can be beneficial —it can
                            target needs resulting from unforeseen circumstances. But, unless the use
                            of discretion is well documented and made public it could undermine the
                            credibility of the allocation process. For example, in one recently
                            completed allocation cycle in Texas senior managers overrode over half
                            the decisions made through the allocation process without documenting
                            their decisions.
                        •   A second factor involves the timely use of tax credits. Data from the
                            states, IRS, and a study contracted by HUD suggest that the states may not
                            be fully using their tax credit allocations. The data show a significant gap
                            between the amount of tax credits that have been allocated by the states
                            to proposed projects and the tax credits that have been awarded to
                            projects when they were completed and been placed in service. For
                            example, IRS data showed that the cohort of projects proposed in 1992
                            received tax credit allocations of about $322 million. However, by the end
                            of calendar year 1994 only about half the credits had been actually
                            used—that is, awarded to projects placed in service. These data raise the
                            question of whether the allocating agencies produced the total amount of
                            housing that the federal government was prepared to fund. From the
                            available data, we cannot determine how much of the total federal
                            allocation that has not been awarded may have lapsed and how much may
                            have been reallocated for future use.
                        •   A third factor involves the long-term economic viability of the tax credit
                            projects after the 15 year tax credit compliance period ends. Under the
                            Code, projects receiving tax credits are required to have an extended-use
                            agreement requiring that the property serve low-income tenants for 30
                            years, but with a contingency clause that allows for conversion to market

                            Page 5                                                 GAO/T-GGD/RCED-97-149
                           Tax Credits: Opportunities to Improve
                           Oversight of the Low-Income Housing

                           rate housing after 15 years under certain conditions. Within the next
                           decade, the first properties subsidized with tax credits will enter the
                           period covered by extended-use agreements. Whether these properties
                           convert to market rate housing, continue to provide high-quality housing
                           for low-income tenants, or gradually deteriorate will depend on such
                           factors as the economics of the alternative uses, the states’ ability to find
                           buyers willing to keep the properties in low-income use, and the need to
                           obtain additional subsidies.

                           All states had some cost control procedures in place that were intended to
State Controls for         help ensure the reasonableness of tax credit awards. However, we
Ensuring the               identified opportunities for the states to improve their cost controls.
Reasonableness of          Figure 5, which is attached to this statement, provides an overview of the
                           development costs or uses of funds and the financing or sources of funds
Project Costs Can Be       for projects placed in service from 1992 through 1994. The height of the
Strengthened               bars represents total development costs or the uses of funds. The
                           financing of these development costs, the sources of funds, was provided
                           by the three components shown:

                       •   Equity paid into projects by tax credit investors, which was about
                           $3.1 billion and which was generated by about $6.1 billion in tax credits
                           investors can claim on their tax returns over 10 years.
                       •   Commercial mortgage loans of about $3.8 billion.
                       •   Concessionary financing of about $3.8 billion, which was provided
                           primarily by other federal housing programs.

                           Controlling the amount of tax credits awarded to individual projects limits
                           federal taxpayers’ cost for the project and allows a state, with an overall
                           tax credit allocation proportional to its population, to finance more
                           projects. To do this the states should consider

                       •   the reasonableness of a project’s development cost;
                       •   the extent of a project’s financing gap, which is the difference between the
                           cost of a project and the amount of non-tax credit financing that a project
                           can raise to cover those development costs; and
                       •   the yield obtained from a project’s tax credit award, which is the amount
                           of equity investment a project could raise for each tax credit dollar

                           All state agencies had controls over development costs. Many states relied
                           on HUD cost standards, others believed their own standards were more

                           Page 6                                                   GAO/T-GGD/RCED-97-149
Tax Credits: Opportunities to Improve
Oversight of the Low-Income Housing

effective in limiting costs, and some relied on their staffs’ expertise
because they said that differences in project types and location made
setting standards impractical. These standards acted as a ceiling on costs.
Additionally, most supplemented these practices by using competition
among project developers to control costs, i.e., cost was a factor in
ranking projects applying for tax credit awards. State agency practices for
determining the reasonableness of the non-tax credit financing varied, but
they generally included reviewing projects’ rents and operating expenses,
private mortgage terms, and non-tax credit public subsidies—in the case
of HUD financing the evaluation is called a “subsidy layering review”.

As already mentioned, the equity yield per dollar of tax credit is a factor
influencing the federal cost of an individual project and the $3.1 billion in
equity paid in by investors during 1992 through 1994 was generated by
$6.1 billion in tax credits. This works out to about $0.53 on the dollar.
States generally relied on the market to determine the yield obtained from
a project’s tax credit award. The tax credit yield or price has gone up over
time, from about $0.45 in 1987 to over $0.60 in 1996, according to several
major syndicators and state allocating agency officials.

In controlling costs—that is, in evaluating the reasonableness of project
costs, the financing gap, and the tax credit price—allocating agencies are
largely dependent on information submitted by developers. To the extent
that the agencies do not have complete and reliable information, they lack
assurance about the effectiveness of their cost controls.

We found some control weaknesses in terms of the way states assured the
reliability of information from developers about their sources and uses of
project funds. For example, although all but one state required some form
of independent verification of cost and financing data, the scope of the
required cost verification work varied. It ranged from audits to more
limited work, that did not require verification of costs included in the base
for calculating the tax credit award. Overall, we estimated that for about
14 percent of the total projects, the states lacked complete information on
the sources and uses of project funds. Without assurance of the validity of
developer costs and without a complete and documented basis for
determining equity needs, such as a detailed sources and uses of funds
analysis, states are vulnerable to providing more (or fewer) credits to
projects than needed.

Accordingly, we recommended that the Commissioner of Internal Revenue
amend regulations for the tax credit program to establish clear

Page 7                                                  GAO/T-GGD/RCED-97-149
                            Tax Credits: Opportunities to Improve
                            Oversight of the Low-Income Housing

                            requirements for ensuring independent verification of key information on
                            sources and uses of funds submitted to states by developers.

                            The Internal Revenue Code provides for dual oversight of the tax credit
State and IRS               program by state tax credit allocating agencies and IRS. In general, we
Oversight Can Be            found that not all allocating agencies fulfilled the requirements of their
Improved                    compliance monitoring programs; and although IRS has been developing
                            programs, it did not have sufficient information to determine state or
                            taxpayer compliance.

State Monitoring Programs   In general states are responsible for monitoring project compliance with
                            rent, income, and habitability requirements after the projects are placed in
                            service and for reporting any noncompliance to IRS. In 1995, several states
                            did not do the number of desk reviews and on-site inspections they had
                            agreed to do. Because IRS’ regulations do not require states to submit
                            annual reports to IRS on the number of monitoring inspections made, IRS
                            was not in a position to readily determine whether states met their
                            agreed-upon monitoring responsibilities. Also, IRS’ monitoring regulations
                            do not require states to make on-site visits to projects or obtain
                            information from other sources, such as local government reports on
                            building code violations, that would allow states to detect violations of the
                            Code’s habitability requirements. For IRS to better ensure that habitability
                            problems are identified during monitoring reviews, states would have to
                            do on-site inspections or obtain information on these types of problems
                            from other sources. We also found that IRS was not collecting enough
                            information from states on the number of units in each project where
                            states found noncompliance for IRS to determine whether the
                            noncompliance has a tax consequence for the project owners.

                            Accordingly, we recommended that the Commissioner of Internal Revenue
                            amend regulations for the tax credit program to (1) require that states
                            report sufficient information about monitoring inspections or reviews,
                            including the number and types of inspections made, so that IRS can
                            determine whether states have complied with their monitoring plans; and
                            (2) require that states’ monitoring plans include specific steps that will
                            provide information to permit IRS to more effectively ensure that the
                            Code’s habitability requirements are met. We also recommended that IRS
                            explore modifying the form states use to report noncompliance so that IRS
                            can better determine whether the noncompliance has a tax consequence
                            for the project owners.

                            Page 8                                                 GAO/T-GGD/RCED-97-149
                           Tax Credits: Opportunities to Improve
                           Oversight of the Low-Income Housing

IRS Compliance Oversight   IRS is responsible for ensuring that taxpayers claim only those tax credits
Activities                 for which they are entitled and for ensuring that states do not exceed their
                           annual tax credit ceilings.

                           In 1995, IRS instituted an audit program to determine whether taxpayers
                           are entitled to the credits claimed on their tax returns. As of the end of
                           fiscal year 1996, IRS had completed work on 35 audit cases and found 12 to
                           be in noncompliance.

                           IRS is relying on the results of its audit initiative to provide estimates on the
                           extent and types of noncompliance that exist in the tax credit program. It
                           is important for IRS to have information on compliance so that it can
                           determine how best to allocate its compliance resources. However, IRS’
                           current audit program is not based on a random sample of returns and will
                           not provide statistically reliable compliance data.

                           With respect to monitoring state use of tax credits, IRS is currently
                           developing a document matching program using state tax credit reports to
                           determine whether states have allocated more credits than allowed by law.
                           However, the reports do not contain information on the allocation year of
                           the tax credits that developers returned to the allocating agencies for
                           reallocation to other projects. IRS needs this information in order to
                           determine whether states stay within their tax credit ceilings. Collecting
                           this additional data on returned credits would also allow IRS to determine
                           whether the states are fully using their tax credit allocations. As I
                           indicated earlier, a significant gap exists between the amount of tax
                           credits that have been allocated by states and the amount of credits that
                           states and IRS records show were awarded to projects that were placed in

                           To supplement its tax credit audit initiative, IRS is exploring the possibility
                           of computer-matching these data against tax credit amounts reported on
                           housing project partnership returns. However, this match would not detect
                           noncompliance at the partner level. But overreporting of tax credits by
                           partners could be detected by matching tax credits reported on the
                           Schedule K-1s, which shows the individual partners’ credit allocations, to
                           the partners’ income tax returns. In a June 1995 report on partnership
                           compliance, we recommended that IRS match Schedule K-1 to tax returns.1
                           However, resource constraints have prevented IRS from transcribing all the

                            Tax Administration: IRS’ Partnership Compliance Activities Could be Improved (GAO/GGD 95-151,
                           June 16, 1995).

                           Page 9                                                                GAO/T-GGD/RCED-97-149
                       Tax Credits: Opportunities to Improve
                       Oversight of the Low-Income Housing

                       Schedule K-1s reporting tax credits it receives so that it could have an
                       effective matching program.

                       Accordingly, we recommended that the Commissioner of Internal Revenue
                       (1) explore alternative ways to develop an estimate of tax credit
                       compliance so that IRS can better determine the resources needed to
                       address noncompliance and (2) explore alternative ways to obtain better
                       information to verify that states’ allocations do not exceed tax credit

                       Unlike most programs operated by state and local governments that
Independent            receive federal financial assistance, the low-income housing tax credit
Oversight of the Tax   program is not covered by the Single Audit Act. The Single Audit Act,
Credit Program         which is an important accountability tool for the hundreds of billions of
                       dollars of federal financial assistance administered by state and local
                       governments and nonprofit organizations, does not apply to tax credits
                       because credits are not considered federal financial assistance under the
                       Office of Management and Budget’s implementing guidance. Subjecting
                       the low-income housing tax credit program to the single audit process may
                       be a more efficient, effective, and less federally intrusive way of
                       monitoring state agency controls than other types of independent audits.

                       Accordingly, to help ensure appropriate oversight of state allocating
                       agencies’ overall compliance with tax credit laws and regulations, we
                       recommended that the Director, Office of Management and Budget,
                       incorporate the low-income housing tax credit program in the definition of
                       federal financial assistance included in implementing guidance for the
                       Single Audit Act so that the program would be subject to audits conducted
                       under the Single Audit Act.

                       Madam Chairman, this concludes my prepared statement. I would be
                       pleased to answer any questions.

                       Page 10                                                GAO/T-GGD/RCED-97-149
Page 11   GAO/T-GGD/RCED-97-149
Figures Used in GAO’s Low-Income Housing
Tax Credit Testimony

              Figure 1: Transferring Tax Credits From the Federal Government to the
Figures       Private Sector

              Figure 2: Estimated 1996 Incomes of Households in Tax Credits Units

              Figure 3: Estimated Average Per-Unit Credit Costs of Properties Placed in
              Service, 1992-94

              Figure 4: Estimated Average Per-Unit Develpment Costs of Tax Credit
              Properties Placed in Service, 1992-94

              Figure 5: Estimates on Housing Project Sources and Uses of Funds

              Page 12                                              GAO/T-GGD/RCED-97-149
                                           Figures Used in GAO’s Low-Income Housing
                                           Tax Credit Testimony

                                                                               Money (equity)

                                                                                     Tax benefits       Investors
                                                                                     (tax credits &   (Corporations)
                                                               Syndicator            deductions)
                                                          (General partner of an
                                                         investment partnership)

                                                                                     Tax benefits       Investors
                                                                                     (tax credits &    (Individual)

                                                         Money                Money (equity)
                                                                         4 Tax benefits
                                                                           (tax credits &
                                  Lender                                                              State housing
                     Loan                       Loan

                                                                                                                 1 Tax benefits
                                                                                                                   (tax credits)

                                                       2 Housing project
                                                         proposal submission
Rent                                                                                                       IRS
                                                       3 Tax benefits
                                                         (tax credits)
                             (General partner
                              of the project)

          Money (equity financing/rent)
          Tax benefits (tax credits/deductions)
          Housing project proposal submission

                                           Page 13                                                        GAO/T-GGD/RCED-97-149
Figures Used in GAO’s Low-Income Housing
Tax Credit Testimony

Percent of households





























Household current income in dollars

Page 14                                                                                    GAO/T-GGD/RCED-97-149



Page 15
                        $1                00
                          0,                0
                                                                                    Percent of units

                                                                                                       Tax Credit Testimony

                        $2              99
                        $3              99
                        $4            ,9
                                                                                                       Figures Used in GAO’s Low-Income Housing

                        $5            ,9
                        $6            ,9
                        $7              99




Page 16
                           $2              ,00
                             0,0               0
                           $4             9,9
                                                                           Percent of units

                             0,0              99
                                                                                              Tax Credit Testimony

                          $6              9,9
                             0,0              99
                          $8                  99
                        $1             $9
                                                                                              Figures Used in GAO’s Low-Income Housing

                          00              9,9
                             ,00             99
                        $1                   99
                        $1                9,9
                          40                  99

           Figures Used in GAO’s Low-Income Housing
           Tax Credit Testimony

           Dollars in billions

                                  10.7                                     10.7






                            Sources of funds to                       Uses of funds to
                             balance projects                         develop projects

                                   Equity investments raised                 Construction expenses
                                   through the award of tax credits
                                   Commercial mortgage loans                 Construction-related fees
                                   Concessionary financing                   Other
                                   (e.g., CDBG loans) and other              (e.g., acquisition of property)

(268796)   Page 17                                                                 GAO/T-GGD/RCED-97-149
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