Current through Register Vol. 49, No. 9, September, 2024
ARKANSAS DEPARTMENT OF PARKS, HERITAGE AND
TOURISM DIVISION OF ARKANSAS HERITAGE ARKANSAS HISTORIC PRESERVATION
PROGRAM
RULES GOVERNING THE ARKANSAS MAJOR HISTORIC
REHABILITATION INCOME TAX CREDIT ACT
I.
PURPOSE
Pursuant to Arkansas Laws Act 855 of 2019, the Division of
Arkansas Heritage through its Arkansas Historic Preservation Program hereby
establishes these rules governing the three part application process for which
the Owner of a historic Arkansas property may apply for an income tax credit
under The Arkansas Major Historic Rehabilitation Income Tax Credit Act.
II.
ENABLING
LEGISLATION
Arkansas Code Annotated $ 19-5-1150 (Act 855 of 2019) created
on the books of the Treasurer of State, the Auditor of State, and the Chief
Fiscal Officer of the State, a trust fund known as the "Arkansas Major Historic
Rehabilitation Trust Fund".
Arkansas Code Annotated $ 26-51-2601
et seq.
(Act 855 of 2019), the "Arkansas Major Historic Rehabilitation Income Tax
Credit Act", allows a credit against the Arkansas Income Tax Act of 1929, Ark.
Coe Ann. $$
26-51-101 -
26-51-2510 and the Insurance
Premium Tax levied under $$
26-57-603 -
26-57-605;
III.
DEFINITIONS
"Act" means Ark. Acts, No. 855 as codified at
Arkansas Code Annotated $ 19-5-1150 and at $ 26-51-2601
et
seq., as such may be amended from time to time.
"AHPP" means the Arkansas Historic Preservation
Program, an agency of the Division of Arkansas Heritage ("DAH") under the
Arkansas Department of Parks, Heritage & Tourism.
"Application" means the Arkansas Major Historic
Rehabilitation Tax Credit Application that constitutes a written plan for
development and operation of a Rehabilitation project. Applications are
submitted in three parts:
1.
Determination of Eligibility (Part 1) is used by the AHPP to determine whether
a property is of historic significance and eligible to receive tax credits.
Upon approval of a Part 1, the AHPP will issue a certificate of
eligibility.
2. Proposed
Rehabilitation Project (Part 2) is used by AHPP to determine whether a proposed
Rehabilitation project will comply with the
Secretary of the Interior's
Standards for the Treatment of Historic Properties with Guidelines for
Preserving, Rehabilitating, Restoring & Reconstructing Historic
Buildings (as used herein, the
"Secretary's
Standards"). See
https://www.nps.gov/tps/standards/treatment-guidelines-2017.pdf
3. Completed Rehabilitation Project (Part 3)
is used by AHPP to determine whether a completed Rehabilitation project
successfully complied with the
Secretary's Standards. Upon
approval of a Part 3, the AHPP will issue a Certificate of Completion. Holders
will submit Certificates of Completion to the appropriate taxing authority to
claim tax credits.
''Arkansas Major Historic Rehabilitation Income Tax
Credit" means the income tax credit allowed under this subchapter
against the income tax imposed by this chapter and the Premium Tax levied under
$$ 26-57-601 -
26-57-605;
"Certification of Completion" means a certificate
issued by the Division of Arkansas Heritage certifying that a project is a
Certified Rehabilitation of an Eligible Property that qualifies for the
Arkansas Major Historic Rehabilitation Income Tax Credit;
"Certified Rehabilitation" means the total of
appropriate and approved Rehabilitation work on an Eligible Property that
results in a substantial rehabilitation of an Eligible Property that has been
issued an eligibility certificate.
"Eligible Property" means property that is located
in the state that:
(A) Qualifies as a
certified historic structure under 26 U.S.C. $ 47, as it existed on January 1,
2019;
(B) Will qualify as a
certified historic structure following Certified Rehabilitation;
(C) Is listed in the National Register of
Historic Places;
(D) Is designated
as contributing to a district listed in the National Register of Historic
Places; or
(E) Is eligible for
designation as contributing to a district listed in the National Register of
Historic Places following Certified Rehabilitation.
"Federal Rehabilitation Tax Credit" means the
federal tax credit provided under 26 U.S.C. $ 47, as it existed on January 1,
2009;
"Historic District" means a geographically
definable area, urban or rural, that possesses a significant concentration,
linkage or continuity of sites, buildings, structures or objects united
historically or aesthetically by plan or physical development. A district may
also comprise individual elements separated geographically during the period of
significance but linked by association or function.
"Holder" means the holder of a Certification of
Completion that is:
(A) A person,
firm, or corporation subject to the income tax imposed by this chapter;
or
(B) An insurance company paying
the Premium Tax on its gross premium receipts;
"Income Tax Credits" means the authorized amount
that may be applied against Arkansas income tax or Premium Tax, whether earned
by an individual, partnership, limited liability company, S Corporation or
Corporation.
"National Register" or "National Register of
Historic Places" means the National Register of districts, sites,
buildings, structures, and objects significant in American history,
architecture, archeology, engineering, and culture pursuant to section
101(a)(1) of the National Historic Preservation Act of 1966, as amended. (The
procedures of the National Register appear in 36 CFR part 60 et
seq.)
"Owner" means a person or an entity that owns
Eligible Property and is the initial recipient of the Certification of
Completion from the Division of Arkansas Heritage;
"Premium Tax" means a tax levied under Ark. Code
Ann. $$ 26-57-603 -
26-57-615;
"Qualified Rehabilitation Expenses" means costs
and expenses incurred to complete a Certified Rehabilitation that are Qualified
Rehabilitation Expenses under the Federal Rehabilitation Tax Credit or under
the Arkansas Major Historic Rehabilitation Income Tax Credit.
"Rehabilitation" means the process of returning a
building or buildings to a state of utility, through repair or alteration,
which makes possible an efficient use while preserving those portions and
features of the building and its site and environment which are significant to
its historic, architectural, and cultural values.
"State Historic Preservation Officer" (SHPO) means
the Director of the Division of Arkansas Heritage, or other official designated
by the Governor or statute to act as liaison for purposes of administering
historic preservation programs within Arkansas.
"Tourism Attraction" means cultural or historical
site, recreational or entertainment facility, area of natural phenomenon or
scenic beauty, theme park, amusement or entertainment park, indoor or outdoor
play or music show, botanical gardens, or cultural or educational
centers.
IV.
DELEGATION OF
AUTHORITY
A. The State
Historic Preservation Officer is delegated all powers necessary and convenient
to carry out the responsibilities contained in these rules.
B. The Arkansas Department of Finance and
Administration and the Arkansas State Insurance Department are responsible for
all procedures, legal determinations, and rules concerning the tax consequences
relating to the Act. Any certification made by the State Historic Preservation
Officer pursuant to the Act or these rules shall not be considered as binding
upon the Arkansas
Department of Finance and Administration and the Arkansas State
Insurance Department with respect to tax consequences.
V.
INTRODUCTION
TO CERTIFICATIONS OF ELIGIBILITY AND REHABILITATION
A. Who may apply:
1. Ordinarily, only the fee simple Owner of
the property in question may apply for the certifications herein described.
However, if an Application is made by someone other than the fee simple Owner,
the Application must be accompanied by a written statement from the fee simple
Owner indicating that the Owner is aware of the Application and has no
objection to the request for certification.
2. Upon receipt of an Application, the AHPP
may determine whether a particular structure qualifies as an Eligible Property.
The AHPP shall do so, however, only after notifying the Owner of the request,
informing such Owner of the possible tax consequences of such a decision, and
permitting the Owner a 30-day time period to submit written comments to the
AHPP prior to decision. Such time period for comment may be waived by the
Owner.
3. Owners of properties that
appear to meet National Register criteria, but are not yet listed in the
National Register or are located within potential Historic Districts, may
request preliminary determinations of historic significance from the AHPP as to
whether such structures may qualify as Eligible Properties when and if the
properties or the potential Historic Districts in which they are located are
listed in the National Register. Preliminary determinations may also be
requested for properties outside the period or area of historic significance of
registered Historic Districts. Procedures for obtaining these determinations
shall be the same as those herein described. Such determinations are
preliminary only and are not binding on the AHPP. Preliminary determinations
will become final as of the date of the listing of the property, or district,
in the National Register. For properties outside the period or registered
Historic District, preliminary determinations will become final, except as
provided below, when the district documentation on file with the National Park
Service ("NPS") is formally amended. If during review of a request for a
Certificate of Rehabilitation, it is determined that the property does not
contribute to the historic significance of the district because of changes that
occurred after the preliminary determination of historic significance was made,
Eligible Property designation will be denied.
4. Owners of structures not yet designated
Eligible Properties may obtain determinations from the AHPP on whether
Rehabilitation proposals meet the Secretary's Standards. Such
determinations will be made only when the Owner has requested a preliminary
determination of the historic significance of the property as described above
and such request for determination has been acted upon by the AHPP. Final
certifications of Rehabilitation will be issued only to Owners of Eligible
Properties.
5. Owners of properties
who have not taken a Rehabilitation tax credit on the Eligible Property within
the past 24 months.
B.
How to apply:
1. Requests for certifications
of eligibility and of Rehabilitation shall be made on Major Historic
Preservation Certification Applications. Part 1 of the Application shall be
used in requesting a certification of eligibility and for preliminary
determinations of eligibility; while Part 2 of the Application shall be used in
requesting an evaluation of a proposed Rehabilitation project.
2. Application forms are available by
contacting AHPP and requesting a hard copy or an electronic version via e-mail.
It is important that an applicant contact AHPP staff prior taking any action on
the proposed tax credit project.
3.
Applications should be reviewed within 30 days of receipt of a complete,
adequately documented Application. Where adequate documentation is not
provided, the Owner will be notified of the additional information needed to
undertake or complete review. The time periods in this part are based on the
receipt of a complete Application. They will be adhered to as closely as
possible and are defined as calendar days. They are not, however, considered to
be mandatory, and the failure to complete review within the designated periods
does not waive or alter any certification requirement. It is the applicant's
responsibility to notify the State Historic Preservation Officer if Application
reviews are not completed within the time periods specified above. The State
Historic Preservation Officer, in turn, will consult with the AHPP to ensure
that the review is completed in as timely manner as possible under the
circumstances.
4. Approval of
Applications and amendments to Applications is conveyed only in writing by duly
authorized officials of the AHPP acting on behalf of the State Historic
Preservation Officer. Decisions with respect to certifications are made on the
basis of the descriptions contained in the Application form and other available
information. In the event of any discrepancy between the Application form and
other, supplementary material submitted with it (such as architectural plans,
drawings, specifications, etc.), the applicant shall be requested to resolve
the discrepancy in writing. In the event the discrepancy is not resolved, the
description in the Application form shall take precedence. Intentional
falsification of factual representations in the Application is subject to
criminal and civil sanctions.
5.
Although certifications of eligibility and Rehabilitation are considered
separately, Owners must submit Part 1 of the Historic Preservation
Certification Application prior to, or with, Part 2. Part 2 of the Application
will not be processed until an adequately documented Part 1 is on file and
acted upon unless the property is already individually listed on the National
Register. Applications will not be considered if the Owner has objected to the
listing of the property in the National Register.
VI.
APPLICATION
PERIOD
A. The Division of
Arkansas Heritage shall accept Applications for the Arkansas Major Historic
Rehabilitation Income Tax Credit beginning July 1, 2020, and ending June
30th, 2025. All tax credit projects must have their
completed Part III Application submitted by May 30th
2025. Any additional work required to bring the project into compliance with
the Secretary's Standards must have been completed and final
documentation submitted for review no later than May
30th, 2025.
B. An Arkansas Major Historic Rehabilitation
Income Tax Credit approved under an Application on or before the June
30th, 2025 date may be carried forward to be claimed
up to five years from the date of issue of the certificate.
VII.
CERTIFICATIONS OF ELIGIBILITY (Part 1
Application)
A. Requests
for certifications of historic significance should be made by the Owner to
determine:
1. That a property located within a
National Register Historic District is of historic significance to such
district; or
2. That a property not
yet listed on the National Register appears to meet National Register criteria;
or
3. That a property located
within a potential Historic District appears to contribute to the historic
significance of such district; and
4. If a property has received a
Rehabilitation tax credit within the past 24 months.
B. To determine whether a property is
individually listed or is part of a district in the National Register, the
Owner may consult the AHPP for current information.
C. If a property is located within the
boundaries of a National Register Historic District and the Owner wishes the
AHPP to certify whether the property contributes or does not contribute to the
historic significance of the district, or if the Owner is requesting a
preliminary determination of eligibility, the Owner must complete Part 1 of the
Historic Preservation Certification Application according to instructions
accompanying the Application. Such documentation includes but is not limited
to:
1. Name and mailing address of the
Owner;
2. Name and address of the
property;
3. Name of the Historic
District;
4. Current photographs of
the property; photographs of the building and its site and landscape features
prior to alteration if Rehabilitation has been completed; photograph(s) showing
the property along with adjacent properties and structures on the street; and
photographs of interior features and spaces adequate to document historic
significance;
5. Brief description
of appearance including alterations, distinctive features and spaces, and
date(s) of construction;
6. Brief
statement of historic significance summarizing how the property does or does
not reflect the values that give the district its distinctive historical and
visual character, and explaining any significance attached to the property
itself (i.e., unusual building techniques, important event
that took place there, etc.).
7. Sketch map clearly delineating the
property's location within the district; and
8. Signature of the Owner requesting or
concurring in a request for evaluation.
D. If a structure is individually listed in
the National Register, it is generally considered an Eligible Property or
certified historic structure and no further certification is required, with the
following exceptions:
1. If the property is
individually listed in the National Register and the Owner believes it has lost
the characteristics that caused it to be nominated and therefore wishes it
delisted, the Owner should refer to the delisting procedures outlined in the
U.S. Code of Federal Regulations at 36 CFR part 60.
2. Some properties individually listed in the
National Register include more than one structure. In such cases, the Owner
must submit a single Part 1 Application and include descriptions of all the
buildings within the listing. The AHPP will determine which of the structures
included within the listing are of historic significance to the
property.
E. Properties
containing more than one structure where the structures are judged by the AHPP
to have been functionally related historically to serve an overall purpose
(such as a mill complex or a residence and carriage house) will be treated as a
single Eligible Property, whether the property is individually listed in the
National Register or is located within a Historic District, when rehabilitated
as part of an overall project. Structures that are functionally related
historically are those which have functioned together to serve an overall
purpose during the property's period of significance. In the case of a property
within a registered Historic District that contains more than one structure
where the structures are judged to be functionally related historically, an
evaluation will be made to determine whether the component buildings contribute
to the historic significance of the property and whether the property
contributes to the significance of the Historic District.
F. Applications for preliminary
determinations for individual listing must show how the property individually
meets the National Register criteria for evaluation. An Application for a
property located in a potential Historic District must document how the
district meets the criteria and how the property contributes to the historic
significance of that district. An Application for a preliminary determination
for a property in a Historic District that is outside the period of
significance in the district documentation on file with the AHPP must document
and justify the expanded historic significance of the district and how the
property contributes to the significance of the district or document the
individual historic significance of the property. Applications must contain
substantially the same level of documentation as National Register nominations,
as specified in the U.S. Code of Federal Regulations at 36 CFR part 60 and
National Register Bulletin 16, Guidelines for Completing National
Register of Historic Places Forms (available from the AHPP).
Owners should understand that intent to nominate to the
National Register, or amend an existing National Register listing, does not
constitute listing in the National Register, nor does it constitute a
certification of eligibility as required by law for tax incentives. Owners
should further understand that they are proceeding at their own risk. If the
property or district is not listed in the National Register for procedural,
substantive or other reasons; if the district documentation is not formally
amended; or if the historic significance of the property has been lost as a
result of alterations or damage, these preliminary determinations of
significance will not become final. The State Historic Preservation Officer
must nominate the property or the district before the preliminary certification
of eligibility can become final.
G. The AHPP discourages the moving of
historic buildings from their original sites. However, if a building is to be
moved as part of a Rehabilitation project for which certification is sought,
the Owner must follow different procedures depending on whether the building is
individually listed in the National Register or is within a Historic District.
When a building is moved, every effort should be made to re-establish its
historic orientation, immediate setting, and general environment. Moving a
building may result in removal of the property from the National Register or,
for buildings within a Historic District, denial or revocation of a
certification of eligibility. Consequently, a moved building may, in certain
circumstances, be ineligible for tax credits.
H. Documentation must be submitted that
demonstrates:
1. The effect of the move on the
building's integrity and appearance (any proposed demolition, proposed changes
in foundations, etc.);
2.
Photographs of the site and general environment of the proposed site; Evidence
the proposed site does not possess historical significance that would be
adversely affected by the moved building;
3. The effect of the move on the distinctive
historical and visual character of the district, where applicable;
and
4. The method to be used for
moving the building.
For buildings individually listed in the National Register, the
procedures contained in the U.S. Code of Federal Regulations at 36 CFR part 60
must be followed prior to the move, or the building will be removed from the
National Register, will not be considered an Eligible Property, and will have
to be re-nominated to the National Register. The Owner may submit a Part 1
Application in order to receive a preliminary determination from the AHPP of
whether a move will cause the property to be removed from the National
Register. However, preliminary approval of such a Part 1 application does not
satisfy the requirements for property eligibility. The applicant must follow
the remaining National Register procedures to ensure that the moved building
will remain listed in the National Register and retain its status as an
Eligible Property.
If an Owner moves (or proposes to move) a building into a
National Register Historic District or moves (or proposes to move) a building
elsewhere within a Historic District, a Part 1 Application containing the
required information must be submitted. The building to be moved will be
evaluated to determine if it contributes to the historic significance of the
district both before and after the move.
I. Properties within Historic Districts will
be evaluated to determine if they contribute to the historic significance of
the district by Application of the Secretary's Standards for Evaluating
Significance within Historic Districts as listed in the U.S. Code of
Federal Regulations at 36 CFR $67.5.
J. Once the historic significance of a
property located within a registered Historic District or a potential Historic
District has been determined by the AHPP, written notification will be sent to
the Owner in the form of a certification of eligibility.
K. Owners shall report to the AHPP any
substantial damage, alteration or changes to a property that occurs after
issuance of a certification of eligibility and prior to a final Certification
of Completion. The AHPP may withdraw a certification of eligibility, upon
thirty days' notice to the Owner, if a property has been damaged, altered or
changed effective as of the date of the occurrence, the property may also be
removed from the National Register.
VIII.
STANDARDS FOR
EVALUATING SIGNIFICANCE WITHIN HISTORIC DISTRICTS
A. Properties located within Historic
Districts are reviewed by the AHPP to determine if they contribute to the
historic significance of the district by applying the following
Standards for Evaluating Significance within Historic
Districts:1. A building contributing
to the historic significance of a district is one which by location, design,
setting, materials, workmanship, feeling and association adds to the district's
sense of time and place and historical development.
2. A building not contributing to the
historic significance of a district is one which does not add to the district's
sense of time and place and historical development; or one where the location,
design, setting, materials, workmanship, feeling and association have been so
altered or have so deteriorated that the overall integrity of the building has
been irretrievably lost.
3.
Ordinarily, buildings that have been built within the past 50 years shall not
be considered to contribute to the significance of a district unless a strong
justification concerning their historical or architectural merit is given or
the historical attributes of the district are considered to be less than 50
years old.
B. A
condemnation order may be presented as evidence of physical deterioration of a
building, but will not of itself be considered sufficient evidence to warrant
certification of historic non-significance for loss of integrity. In certain
cases it may be necessary for the Owner to submit a structural engineer's
report to help substantiate physical deterioration and/or structural damage.
Guidance on preparing a structural engineer's report is available from the
AHPP.
C. Some properties listed in
the National Register, primarily districts, are resources whose concentration
or continuity possesses greater historical significance than many of their
individual component buildings and structures. These usually are documented as
a group rather than individually. Accordingly, this type of National Register
documentation is not conclusive for the purposes of determining eligibility and
must be supplemented with information on the significance of the specific
property. Certifications of historic significance and non-significance will be
made on the basis of the Application documentation, existing National Register
documentation, and other available information as needed. The AHPP may submit
an amended National Register nomination or the National Park Service if the
Application material warrants such an amendment. If a certification request is
received for a property, which is not yet listed on the National Register or
which is outside a district's established period or area of significance, a
preliminary determination of eligibility will be issued only if the request
includes adequate documentation and if there is written assurance that the
Owner plans to nominate the property or district or that the district
nomination in question is being revised to expand its significance.
Certifications will become final when the property or district is listed or
when the district documentation is officially amended, unless the historic
significance of the property has been lost as a result of alteration or damage.
For procedures on amending listings to the National Register and additional
information on the use of National Register documentation, Owners should
contact the AHPP.
D. Where
Rehabilitation credits are sought, certifications of eligibility will be made
on the appearance and condition of the property before Rehabilitation was
begun.
E. If a non-historic surface
material obscures a facade, it may be necessary for the Owner to remove a
portion of the surface material prior to requesting certification so that a
determination of historic significance or non-significance can be made. After
the material has been removed, if the obscured facade has retained substantial
historic integrity and the property otherwise contributes to the Historic
District, it will be determined to be an Eligible Property.
IX.
CERTIFICATIONS OF PROPOSED REHABILITATION (Part 2
Application)
A. Owners who
want Rehabilitation projects for Eligible Properties to be certified by the
AHPP as being consistent with the historic character of the structure, and,
where applicable, the district in which the structure is located, thus
qualifying as a Certified Rehabilitation, shall comply with the procedures
listed below:
1. To initiate review of a
Rehabilitation project for certification purposes, an Owner must complete Part
2 of the Historic Preservation Certification Application according to
instructions accompanying the Application. The Application may describe a
proposed Rehabilitation project, a project in progress, or a completed
project.
2. These instructions
explain in detail the documentation required for certification of a
Rehabilitation project. In all cases, documentation, including photographs
(color processed photographs) adequate to document the appearance of the
structure(s), both on the exterior and on the interior, and its site and
environment prior to Rehabilitation must accompany the Application. The social
security or taxpayer identification number(s) of all Owners must be provided in
the Application. Other documentation, such as window surveys or cleaning
specifications, may be required by the AHPP to evaluate certain Rehabilitation
projects. Plans for any attached, adjacent, or related new construction must
also accompany the Application. Where necessary documentation is not provided,
review and evaluation may not be completed and a denial of certification will
be issued on the basis of lack of information.
3.
Owners are strongly encouraged to
submit Part 2 of the Application prior to undertaking any Rehabilitation work.
Owners who undertake Rehabilitation projects without prior review and approval
from the AHPP do so strictly at their own risk. Because the
circumstances of each Rehabilitation project are unique to the particular
certified historic structure involved, certifications that may have been
granted to other Rehabilitations are not specifically applicable and may not be
relied on by Owners as applicable to other projects.
4. A project does not become a Certified
Rehabilitation until it is completed and so designated by the AHPP. A
determination that the completed Rehabilitation of a structure not yet
designated an Eligible Property meets the Secretary's
Standards does not constitute a Certification of Completion. When
requesting certification of a completed Rehabilitation project, the Owner shall
submit a Request for Certification of Completion (Part 3) and provide the
project completion date and a signed statement that the completed
Rehabilitation project meets the Secretary's Standards and is
consistent with the work described in Part 2 of the Major Historic Preservation
Certification Application. Also required in requesting Certification of
Completion are costs attributed to the Rehabilitation, photographs adequate to
document the completed Rehabilitation, and the social security or taxpayer
identification number(s) of all Owners.
B. For certification purposes, a
Rehabilitation project encompasses all work on the interior and exterior of the
Eligible Property and its site and environment, as determined by the AHPP, as
well as related demolition, new construction or Rehabilitation work, which may
affect the historic qualities, integrity or site, landscape features, and
environment of the Eligible Property. More specific considerations in this
regard are as follows:
1. All elements of the
Rehabilitation project must meet the Secretary's Standards for Rehabilitation;
portions of the Rehabilitation project not in conformance with the Standards
may not be exempted. In general, an Owner undertaking a Rehabilitation project
will not be held responsible for prior Rehabilitation work not part of the
current project or Rehabilitation work that was undertaken by previous Owners
or third parties.
2. However, if
the AHPP considers, or has reason to consider, that a project submitted for
certification does not include the entire Rehabilitation project subject to
review hereunder, the AHPP may choose to deny a Certificate of Completion or to
withhold a decision on such a certification until such time as the AHPP has
determined the proper scope of the Rehabilitation project to be reviewed.
Factors to be taken into account by the AHPP in this regard include, but are
not limited to, the facts and circumstances of each Application and:
a. whether previous demolition, construction
or Rehabilitation work irrespective of ownership or control at the time was in
fact undertaken as part of the Rehabilitation project for which certification
is sought; and
b. whether property
conveyances, reconfigurations, ostensible ownership transfers or other
transactions were transactions which purportedly limit the scope of a
Rehabilitation project for the purpose of review by the AHPP without
substantially altering beneficial ownership or control of the property. The
fact that a structure may still qualify as an eligible after having undergone
inappropriate Rehabilitation, construction or demolition work does not preclude
the AHPP from determining that such inappropriate work is part of the
Rehabilitation project to be reviewed.
3. Conformance to the Standards will be
determined on the basis of the Application documentation and other available
information by evaluating the property as it existed prior to the commencement
of the Rehabilitation project, regardless of when the structure becomes or
became an Eligible Property.
4. For
Rehabilitation projects involving more than one Eligible Property where the
structures are judged by the AHPP to have been functionally related
historically to serve an overall purpose (such as a mill complex or a residence
and carriage house) a Certification of Completion will be issued on the merits
of the overall project rather than for each structure or individual component.
For Rehabilitation projects where there is no historic functional relationship
among the structures, the decision will be made for each separate Eligible
Property regardless of how they are grouped for ownership or development
purposes.
5. Demolition of a
building as part of a Rehabilitation project involving multiple buildings may
result in denial of a Certification of Completion. In projects where there is
no historic functional relationship among the structures being rehabilitated,
related new construction which physically expands one Eligible Property
undergoing Rehabilitation and, therefore, directly causes the demolition of an
adjacent structure, will generally result in denial of a Certification of
Completion unless a determination has been made that the building to be
demolished is not an Eligible Property. In Rehabilitation projects where the
structures have been determined to be functionally related historically,
demolition of a component may be approved, in limited circumstances, when:
a. The component is outside the period of
historic significance of the property, or
b. The component is so deteriorated or
altered that its integrity has been irretrievably lost; or
c. The component is a secondary one that
generally lacks historic, engineering, or architectural significance or does
not occupy a major portion of the site and persuasive evidence is present to
show that retention of the component is not technically or economically
feasible.
6. In
situations involving Rehabilitation of an Eligible Property in a Historic
District, the AHPP will review the Rehabilitation project first as it affects
the Eligible Property and second as it affects the district and make a decision
accordingly.
7. In the event that
an Owner of a portion of an Eligible Property requests a certificate of
completion related only to that portion, but there is or was a larger related
Rehabilitation project(s) occurring with respect to the Eligible Property,
AHPP's decision on the requested Certification of Completion will be based on
review of the overall Rehabilitation project(s) for the Eligible Property.
C. Upon receipt of the
complete Application describing the Rehabilitation project, the AHPP shall
determine if the project is consistent with the Secretary's
Standards. If the project does not meet the Secretary's
Standards, the Owner shall be advised of that fact in writing and,
where possible, will be advised of necessary revisions to meet such
standards.
D. Once a proposed or
ongoing project has been approved, substantive changes in the work as described
in the Application must be brought promptly to the attention of the AHPP by
written statement to ensure continued conformance to the Secretary's
Standards. The AHPP will notify the Owner in writing whether the
revised project continues to meet these standards. Oral approvals of revisions
are not authorized or valid.
E.
Projects in progress may be inspected by an authorized representative of the
State Historic Preservation Officer to determine if the work meets the
Secretary's Standards. The AHPP may deny a Certification of
Completion if it is determined that the Rehabilitation project was not
undertaken as represented by the Owner in the Application.
F. If a proposed, ongoing, or completed
Rehabilitation project does not meet the Secretary's
Standards, an explanatory letter will be sent to the Owner by the
AHPP. A rehabilitated property not in conformance with these Standards and
which is determined to have lost those qualities which caused it to be
nominated to the National Register will be removed from the National Register
in accordance with U.S. Department of the Interior regulations.
G. All Rehabilitation projects seeking tax
credits must address one or more of the Program's priorities. Applications
should indicate which of these priorities their project addresses when
submitting the Part 2 Application. Applications will be prioritized in the
following order:
1. Creation of a new
business
2. Expansion of an
existing business
3. Establishment
of a Tourism Attraction
4.
Revitalization of a commercial Historic District
5. Rehabilitation of a significant property
in a historic neighborhood
X.
STANDARDS FOR
REHABILITATION
A. The
standards for rehabilitation cited herein are the criteria used to determine if
a Rehabilitation project qualifies as a Certified Rehabilitation. The intent of
the standards is to assist the long term preservation of a property's
significance through the preservation of historic materials and features. The
standards pertain to historic buildings of all materials, construction types,
sizes, and occupancy and encompass the exterior and the interior of historic
buildings. The standards also encompass related landscape features and the
building's site and environment, as well as attached, adjacent, or related new
construction. To be certified, a Rehabilitation project must be determined by
the AHPP to be consistent with the historic character of the structure(s) and,
where applicable, the district in which it is located.
B. The following standards are to be applied
to specific Rehabilitation projects in a reasonable manner, taking into
consideration economic and technical feasibility:
1. A property shall be used for its historic
purpose or be placed in a new use that requires minimal change to the defining
characteristics of the building and its site and environment.
2. The historic character of a property shall
be retained and preserved. The removal of historic materials or alteration of
features and spaces that characterize a property shall be avoided.
3. Each property shall be recognized as a
physical record of its time, place, and use. Changes that create a false sense
of historical development, such as adding conjectural features or architectural
elements from other buildings, shall not be undertaken.
4. Most properties change over time. Those
changes that have acquired historic significance in their own right shall be
retained and preserved.
5.
Distinctive features, finishes, and construction techniques or examples of
craftsmanship that characterize a historic property shall be
preserved.
6. Deteriorated historic
features shall be repaired rather than replaced. Where the severity of
deterioration requires replacement of a distinctive feature, the new feature
shall match the old in design, color, texture, and other visual qualities and,
where possible, materials. Replacement of missing features shall be
substantiated by documentary, physical, or pictorial evidence.
7. Chemical or physical treatments, such as
sandblasting, that cause damage to historic materials shall not be used. The
surface cleaning of structures, if appropriate, shall be undertaken using the
gentlest means possible.
8.
Significant archeological resources affected by a project shall be protected
and preserved. If such resources must be disturbed, mitigation measures shall
be undertaken.
9. New additions,
exterior alterations, or related new construction shall not destroy historic
materials that characterize the property. The new work shall be differentiated
from the old work and shall be compatible with the massing, size, scale, and
architectural features to protect the historic integrity of the property and
its environment.
10. New additions
and adjacent or related new construction shall be undertaken in such a manner
that if removed in the future, the essential form and integrity of the historic
property and its environment would be unimpaired.
C. The quality of materials and craftsmanship
used in a Rehabilitation project must be commensurate with the quality of
materials and craftsmanship of the historic building in question. Certain
treatments, if improperly applied, or certain materials by their physical
properties, may cause or accelerate physical deterioration of historic
buildings. Inappropriate physical treatments include, but are not limited to:
improper repointing techniques; improper exterior masonry cleaning methods; or
improper introduction of insulation where damage to historic fabric would
result. In almost all situations, use of these materials and treatments will
result in denial of a Certification of Completion. Similarly, exterior
additions, that duplicate the form, material, and detailing of the structure to
the extent that they compromise the historic character of the structure, will
result in denial. For further information on appropriate and inappropriate
Rehabilitation treatments, Owners are to consult the
Guidelines for
Rehabilitating Historic Buildings published by the U.S. National Park
Service (see
https://www.nps.gov/tps/standards/rehabilitation/rehab/guide.htm).
Technical information to help property Owners formulate plans for the
Rehabilitation, preservation, and continued use of historic properties
consistent with the intent of the
Secretary's Standards is
available from the AHPP. Owners are responsible for procuring this material as
part of planning for a Rehabilitation project.
D. In certain limited cases, it may be
necessary to dismantle and rebuild portions of an Eligible Property to
stabilize and repair weakened structural members and systems. In such cases,
the AHPP will consider such extreme intervention if:
1. The necessity for dismantling is justified
in supporting documentation;
2.
Significant architectural features and overall design are retained;
and
3. Adequate historic materials
are retained to maintain the architectural and historic integrity of the
overall structure. Owners are cautioned that the standards for rehabilitation
require retention of distinguishing historic materials of external and internal
walls as well as structural systems. In limited instances, Rehabilitations
involving removal of existing external walls, (i.e., external
walls that detract from the historic character of the structure such as in the
case of a non-significant later addition or walls that have lost their
structural integrity due to deterioration) may be certified as meeting the
Secretary's Standards.
E. Prior approval of a project by other
state, federal, or local agencies or organizations does not ensure
certification by the AHPP for tax purposes. The Secretary's
Standards take precedence over other regulations and codes in
determining whether the Rehabilitation project is consistent with the historic
character of the property and, where applicable, the district in which it is
located.
F. The qualities of a
structure and its environment which qualify it as an Eligible Property are
determined taking into account all available information, including information
derived from the physical and architectural attributes of the building; such
determinations are not limited to information contained in National Register or
related documentation.
XI.
CERTIFICATION OF
COMPLETION (Part 3 Application)
A. Upon completion of a Rehabilitation
project, the Owner shall submit documentation required by the AHPP to verify
that the completed Rehabilitation qualifies as a Certified Rehabilitation.
1. The Owner shall certify to the AHPP the
validity of costs and expenses claimed as Qualified Rehabilitation Expenses and
shall maintain a record supporting the claim for at least five (5) years after
the issuance of the Certification of Completion.
2. An Owner's record supporting a claim for
Qualified Rehabilitation Expenses may be reviewed by the AHPP, the appropriate
tax collection authority, or a Holder.
B. If the AHPP determines that a completed
Rehabilitation project qualifies as a Certified Rehabilitation and that the
Certified Rehabilitation is complete, the AHPP shall issue a freely
transferable certificate of completion specifying the total amount of the
Qualified Rehabilitation Expenses and Arkansas Major Historic Rehabilitation
Income Tax Credit allowed. Accordingly:
1. The
Arkansas Major Historic Rehabilitation Income Tax Credit allowed shall be an
amount equal to twenty-five percent (25%) of the total Qualified Rehabilitation
Expenses incurred by the Owner to complete the Certified
Rehabilitation.
2. The Division of
Arkansas Heritage shall not issue Arkansas Major Historic Rehabilitation Income
Tax Credits for more than the amount certified under $ 19-5-1150(c) (1) (A).
a. Any unused tax credits shall not be
carried over to the following fiscal year for use by the AHPP or the Division
of Arkansas Heritage.
b. Any
Certification of Completion that would cause the Arkansas Major Historic
Rehabilitation Income Tax Credit to exceed the amounts listed above during the
fiscal year will be carried forward for consideration during the following
fiscal year.
3. The
Arkansas Major Historic Rehabilitation Income Tax Credit shall be available to
an Owner of an Eligible Property that:
a.
Completes a Certified Rehabilitation that is placed in service after January 1,
2019;
b. Has a minimum investment
of one million five hundred thousand dollars ($1,500,000) in Qualified
Rehabilitation Expenses; and
c. Is
not receiving a tax credit under any other state law for the same Eligible
Property.
C.
Upon issuance of a certificate of completion, the AHPP will notify the
appropriate tax authority within fifteen (15) business days.
XII.
CLAIMING
CREDIT/TRANSFERRING CREDIT
A.
1. A
Holder shall submit the certificate of completion and documents proving an
assignment, if any, with the appropriate tax collection authority at the time
of filing the Holder's income tax return or Premium Tax return.
2. The appropriate tax collection authority
may refuse to recognize the Arkansas Major Historic Rehabilitation Income Tax
Credit claimed if the Holder fails to submit the Certification of Completion
and any assignment documents.
B. The amount of the Arkansas Major Historic
Rehabilitation Income Tax Credit that may be used by a Holder for a taxable
year may equal but shall not exceed the amount of income tax or Premium Tax
due.
C. A Holder of an unused
Arkansas Major Historic Rehabilitation Income Tax Credit may carry forward part
or all of an Arkansas Major Historic Rehabilitation Income Tax Credit for five
(5) consecutive taxable years to apply against the Holder's income taxes due or
the Holder's Premium Tax due. The credit will be forfeited after the fifth tax
year from the date of issue of the certificate.
D.
1. An
Owner of an Arkansas Major Historic Rehabilitation Income Tax Credit may freely
transfer, sell, or assign part or all of the Arkansas Major Historic
Rehabilitation Income Tax Credit amount identified in the Certification of
Completion.
2. A subsequent Holder
may transfer, sell, or assign part or all of the remaining Arkansas Major
Historic Rehabilitation Income Tax Credit.
E. An Owner may sell the Owner's Eligible
Property after the issuance of the Certification of Completion.
F. An Arkansas Major Historic Rehabilitation
Income Tax Credit granted to a partnership, Subchapter S corporation, a limited
liability company taxed as a partnership, or multiple Owners of property shall
be passed through to the partners, members, or Owners respectively on a pro
rata basis or pursuant to an executed agreement among the partners, members, or
Owners documenting an alternate distribution method.
G.
1. A
Holder may use the Arkansas Major Historic Rehabilitation Income Tax Credit to
offset up to one hundred percent (100%) of the state income taxes due or
Premium Tax due from the Holder.
2.
A Holder is not required to have any ownership or other interest in the
Eligible Property for which an Arkansas Major Historic Rehabilitation Income
Tax Credit is claimed.
3. An
Arkansas Major Historic Rehabilitation Income Tax Credit may be used up to its
total amount by any Holder without limitation and is not subject to limits
imposed by federal law or regulation on the use of Federal Rehabilitation Tax
Credits.
H. An Owner or
Holder that assigns part or all of an Arkansas Major Historic Rehabilitation
Income Tax Credit shall perfect the transfer by notifying the Division of
Arkansas Heritage and the appropriate tax collection authority in writing
within thirty (30) calendar days following the effective date of the transfer
and shall provide any information as may be required by the Division of
Arkansas Heritage and the appropriate tax collection authority to administer
and carry out the Act and to ensure proper tracking of the ownership of the
unused Arkansas Major Historic Rehabilitation Income Tax Credit.
I.
1. Any
consideration received for the transfer of an Arkansas Major Historic
Rehabilitation Income Tax Credit shall not be deducted from income taxable by
the State of Arkansas.
2. Any
consideration paid for the transfer of an Arkansas Major Historic
Rehabilitation Income Tax Credit shall not be included as income taxable by the
State of Arkansas.
XIII.
FEES
A. The fee for review of a proposed
Rehabilitation project (Part 2) is fifty dollars ($50). This initial review fee
is non-refundable and is due upon submission of a Proposed Rehabilitation
Project (Part 2).
B. The fees for
reviewing Completed Rehabilitation Projects (Part 3) for an income-producing
property are based on the dollar amount of the costs attributed solely to the
Qualified Rehabilitation Expenses on the eligible structure, in accordance with
the schedule below.
Fee Size of Rehabilitation
$400 review fee for $1,500,000 or more
1. The initial fee of $50 will be deducted
from these fees.
2. The balance
shall be paid by the applicant upon submission of the Part 3
Application.
3. No Certification of
Completion shall be issued until the balance due has been paid.
4. No Certification of Completion shall be
issued until the pending Eligible Property has officially been placed on the
National Register, individually or as a contributing structure in a National
Register Historic District.
C. The fee for perfecting the transfer of an
unused tax credit, in whole or in part, is seventy-five hundredths percent
(0.75%) of the amount of tax credit to be transferred.
D. All fees collected will be deposited into
the AHPP's cash funds and may be used for the administration of the Act or as
directed by the AHPP Director.
XIV.
APPEALS
Except as otherwise provided herein, an Owner may appeal any
decision or action of the State Historic Preservation Officer.
A. An Owner appealing the AHPP's
determination of eligibility for listing on the National Register of Historic
Places (Part 1 Application) may appeal to the National Park Service, in
accordance with the procedures set forth in 36 CFR part 60 et
seq. The State Historic Preservation Officer will consider the
determination from the National Park Service to be final.
B. An appeal by the Owner may be made from
any of the certifications or any decisions made pursuant to the Act. Such
appeals must be in writing and received by the State Historic Preservation
Officer within 30 calendar days of receipt of the decision which is the subject
of the appeal. The appellant may request an opportunity for a meeting to
discuss the appeal, but all information the Owner wishes to be considered must
be submitted in writing.
1. The State Historic
Preservation Officer will convene the Rehabilitation Tax Credit Appeals
Committee with 30 calendar days of an Owner's request for an appeal. The
committee will be comprised of the State Historic Preservation Officer or
his/her designee, two members of the State Review Committee for Historic
Preservation, the AHPP director, and the AHPP Federal Programs
Manager.
2. The committee will
consider the record of the decision in question, any further written
submissions by the Owner, and other available information. The committee will
decide by majority vote whether the Application for a Certification of
Completion should be approved and shall provide the appellant a written
decision as promptly as circumstances permit.
3. The committee's decision constitutes an
administrative review of the decision appealed and will not be conducted as an
adjudicative proceeding.