IRS Regulatory Relief Available During COVID-19 Pandemic
On January 15, IRS issued Notice 2021-12 providing temporary relief to state Housing Credit allocating agencies, owners, and residents of Housing Credit properties in response to the COVID-19 pandemic. Notice 2021-12 extends the deadlines and waivers originally provided by IRS under Notice 2020-53 and expands relief measures to include additional relief not previously provided by the Service. This matrix compares the accommodations IRS provides in Notice 2021-12 to recommendations for COVID-19 guidance that NCSHA sent to IRS in a November 16 letter and to existing disaster relief IRS provides under Revenue Procedures 2014-49 and 2014-50, which are applicable in cases of a presidentially-declared major disaster.
NCSHA updated this document on January 18, 2021, to account for Notice 2021-12 — IRS’s most recent guidance related to COVID-19 — and NCSHA’s most recent recommendations to IRS. Previous iterations of this document compared earlier NCSHA recommendations to IRS with IRS guidance available at that time. NCSHA will keep this document updated based on current IRS Housing Credit COVID-19 guidance and NCSHA’s most recent written communication with the Service on this subject.