Travois belongs to two New Markets Tax Credit-focused groups: the NMTC Coalition and the NMTC Working Group. Both organizations recently responded to the IRS’ request for public comments on the effectiveness of the NMTC program.
Now that Travois has passed the $100 million mark in the NMTC program and our clients have done everything from build health centers to salmon processing plants, we had diverse experience to inform our comments.
While the two comment letters represent the consensus among a wide variety of organizations like Travois — community development entities, investors, lawyers and accountants serving every corner of the US — we focused our comments on Indian Country:
- We urged the IRS to keep the NMTC program open to working with other federally supported sources of financing like loan and loan guarantee programs managed by the U.S. Department of Agriculture (USDA) and U.S. Small Business Administration (SBA). We believe Native entrepreneurs are working with multiple agency partners to put their deals together, and we want future policy to support that.
- We provided information on ways to keep the transaction costs of NMTC projects as low as possible in order to deliver as much financial benefit as possible to projects.
All of the commenters discussed ways to open the door to a wider diversity of projects to take advantage of the NMTC program. Travois participated in numerous conference calls and meetings always to ensure that our group comments were in the best interests of American Indian, Alaska Native and Native Hawaiian organizations. Each comment letter ended up representing a nationwide consensus, but Travois believes the comments will also help inform the discussion of how the NMTC can best serve Indian Country.