Rev. Rul. 99-39, 1999-38 I.R.B. 424.

                       Internal Revenue Service
                                 Revenue Ruling

                          LOW-INCOME HOUSING TAX CREDIT

                         Published: September 20, 1999

Section 42.--Low-Income Housing Credit, 26 CFR 1.42-16: Eligible basis reduced by federal grants.

  Low-income housing tax credit. Certain rental assistance payments made to a building owner on behalf of, or in respect to, a tenant under the Housing Opportunities for Persons With AIDS program are not grants made with respect to a building or its operation under section 42(d)(5) of the Code.

  Low-income housing tax credit. This revenue ruling advises taxpayers that certain rental assistance payments made to a building owner on behalf of, or in respect to, a tenant under the Housing Opportunities for Persons With AIDS (HOPWA) program are not grants made with respect to a building or its operation under section 42(d)(5) of the Code.

  Pursuant to § 1.42-16(b)(3) of the Income Tax Regulations, the Internal Revenue Service has determined that certain rental assistance payments made to a building owner on behalf or in respect of a tenant under the Housing Opportunities for Persons With AIDS (HOPWA) program (42 U.S.C. 12901-12912) are not grants made with respect to a building or its operation under § 42(d)(5) of the Internal Revenue Code. These rental assistance payments are provided under 24 C.F.R. 574.300(b)(5).

DRAFTING INFORMATION

  The principal author of this revenue ruling is Christopher J. Wilson of the Office of Assistant Chief Counsel (Pass-throughs and Special Industries). For further information regarding this revenue ruling contact Mr. Wilson on (202) 622-3040 (not a toll-free call).

Rev. Rul. 99-39, 1999-38 I.R.B. 424.