On July 1, 2024, new Missouri Department of Economic Development rules for the Historic Preservation Tax Credit Program took effect, with the purpose of streamlining the application and review processes by improving efficiency, consistency and transparency. These changes apply to new projects submitted on or after July 1, 2024.
On Aug. 28, 2024, new legislation affecting the Missouri Historic Tax Credit Program went into effect as a result of House Bill 2062. This legislation is known as the Missouri Historic, Rural Revitalization and Regulatory Streamlining Act. The state tax credit is equal to 25% of qualified rehabilitation expenditures (QREs) of approved historic structures or, under the new legislation, 35% of QREs if the property is located outside Kansas City or St. Louis City and does not receive or intend to receive low-income housing tax credits. The new legislation also makes nonprofit entities eligible recipients of state historic tax credits, and it exempts historic schools and theaters from the scoring requirements to which other large-cap projects are subjected. For more information, please visit the DED’s Historic Preservation Tax Credit Program webpage.
ARCHITECTURAL PRESERVATION SERVICES
Members of the Architectural Preservation Services Unit in the State Historic Preservation Office provide technical review and guidance related to architectural aspects of projects involved in various programs instituted under the National Historic Preservation Act. Primarily, the unit works with owners, architects and developers to ensure rehabilitation projects qualify for rehabilitation credits through the Federal Historic Preservation Tax Incentives Program and the Missouri Historic Preservation Tax Credit Program. The Architectural Preservation Services Unit (APS) also reviews architectural work associated with historic properties that have state and national easements, properties that are listed as National Landmarks, and projects that are receiving grant funds issued through the Historic Preservation Fund. The APS’ efforts assist in identifying, evaluating and protecting Missouri’s diverse range of historic architectural resources.
For more information, please call 573-751-7860.
HISTORIC PRESERVATION TAX CREDIT PROGRAMS
Two historic preservation tax credits programs are available for historic properties rehabilitated within Missouri. Initiated in 1977, the Federal Historic Preservation Tax Incentives Program provides federal income tax credit to private property owners for qualified rehabilitation projects of certified historic buildings. In 1997, Missouri created the Historic Preservation Tax Credit Program, a similar incentives program that encourages the preservation and continued use of Missouri’s historic architectural resources.
Today, through the Federal Historic Preservation Tax Incentives Program, privately owned income-producing properties determined to be certified historic structures may receive a 20% tax credit for the cost of qualified rehabilitation expenditures. The state historic preservation tax credit provides a 25% tax credit for certified historic structures. The state credit is available to both commercial properties and owner-occupied homes.
FEDERAL HISTORIC PRESERVATION TAX INCENTIVES
WHO QUALIFIES?
- The National Park Service provides a program summary that outlines eligibility.
- Qualified rehabilitation expenditures must meet the IRS definition of a substantial rehabilitation in order to qualify for credit.
- The property must be a certified historic structure as defined by the National Park Service.
- The rehabilitation must meet the Secretary of the Interior’s Standards for Rehabilitation. Applications are subject to a joint review by the SHPO and the NPS. (Note that local historic preservation review boards do not have any review or approval authority for historic preservation tax credit purposes.)
- The property must be income producing and depreciable.
- After rehabilitation, the building must be owned by the same owner and operated as an income-producing property for five years.
MISSOURI HISTORIC PRESERVATION TAX CREDIT PROGRAM
The Missouri State Historic Preservation Tax Credit Program is administered by the Missouri Department of Economic Development. The department provides information regarding state tax credits.
WHO QUALIFIES?
- The Missouri Department of Economic Development provides a program summary that outlines eligibility.
- Any Missouri taxpayer is eligible to participate in the state historic tax credit program. Not-for-profit entities and government entities are ineligible.
- The property must be either listed individually on the National Register of Historic Places or certified as contributing to either a National Register District or a Certified Local District.
- The costs and expenses associated with the rehabilitation must exceed 50% of the total basis of the property (acquisition cost).
- The rehabilitation must meet the Secretary of the Interior’s Standards for Rehabilitation. Applications are subject to a review by the State Historic Preservation Office. (Note that local historic preservation review boards do not have any review or approval authority for tax credit purposes.)
- Owner-occupied properties may be eligible for the Missouri Historic Preservation Tax Credit Program.
Participants are strongly advised to consult a qualified tax adviser, the Missouri Department of Economic Development and the Internal Revenue Service for help in determining tax and financial implications of participation in these programs.
HOW TO APPLY
SUBMITTING FEDERAL HPCA PROJECTS TO THE SHPO FOR REVIEW:
- Download and complete the federal historic preservation certification applications, available from the National Park Service.
- Applications must be completed as outlined in the NPS-issued instructions.
- Failure to provide the information identified on the form may result in the SHPO requesting more information and, therefore, a delay in your project’s review.
- Download and complete the submission checklist.
- Each digital application and all other project material should be provided as separate PDFs with the files named accordingly (e.g., "Maps," "Photos," "Existing Plans" and "Proposed Plans"). Please follow NPS directives for file naming. Mislabeled files will be returned to applicants for correction. Reference the Electronic File Format Standards and File Naming Conventions and Photo Naming Conventions, JPEG Requirements and Photo Sheet Examples.
- Create a new email with the “To” address as MOFederalHTC@dnr.mo.gov and the following subject line format: “Review Request – SHPO project number (if previously assigned), any federally associated project numbers, application part, project title and/or address.” Example: Review Request – 2023-001, 12345 (federally issued number only), Part 2, Historic Property Name, Property Address with City.
- Attach the completed application forms, the submission checklist and your other project material attachments to the email. Note: Our system cannot receive emails exceeding 10 MB in size. If your submission contains large files, you may provide this information to our office via a large-file transfer service such as your organization’s FTP system, Dropbox, One Drive or Google Drive. If your organization does not have access to a large-file transfer service, you may request the SHPO to send you an FTP upload request from the State of Missouri system. Requests should be submitted to MOFederalHTC@dnr.mo.gov. Include the subject line "Request for HTC FTP Upload."
- Press “Send” to email your project submission to the SHPO. Projects received during business hours will be marked as received that day. Projects received outside of business hours will be logged the next business day. SHPO staff will send you an email confirming receipt of your application.
Any questions you may have about the submission process may be sent to MOFederalHTC@dnr.mo.gov, or you may call 573-751-7860.
SUBMITTING MISSOURI HISTORIC PRESERVATION TAX CREDIT PROJECTS FOR REVIEW:
Missouri historic preservation tax credits applicants must submit application material through the Submittable online submission program managed by the Department of Economic Development. For assistance providing photos to accompany historic tax credit applications, click here. These historic tax credit application photo instructions are also available through the Department of Economic Development's “HTC - Preliminary Application Checklist” webpage at ded.mo.gov/media/pdf/htc-preliminary-application-checklist (see Page 4, Item 15: Photos). Once the completed application is processed by the DED, the DED will forward the application materials to the SHPO for review.
Consultation Meetings with Architectural Preservation Services
- Consultations include pre-application reviews and technical guidance.
- SHPO response to a consultation is advisory – i.e., guidance limited to the specific issue(s) requested and the related information provided. It is not a determination and is non-binding. Formal determinations are provided following the formal review of an entire scope of work in a state and/or federal application.
- The facts, circumstances and understanding of a project may change between the time of a preliminary consultation and the submission and review of a Part 2 application.
- Preliminary consultation responses are generally provided verbally.
- Preliminary consultations are not a substitute for an understanding of the Secretary of the Interior’s Standards for Rehabilitation or the use of historic consultants.
Requests for consultation meetings can be arranged by calling 573-751-7860.
All applicants to the Historic Preservation Tax Credit Program are advised to wait for signed approval on their proposed scope of work before undertaking any demolition or construction work on the project. Signed determinations are provided following the formal review of a complete scope of work in a state and/or federal application. Please be advised that any work performed without signed approval is done at your own risk. If you perform work that does not meet the Secretary of the Interior's Standards, it can have financial consequences at the end of the project.
For state historic tax credit applications, approval comes from the Department of Economic Development. For federal historic tax credit applications, signed approval (a signed determination letter) comes from the National Park Service. The SHPO reviews all applications to the Secretary of the Interior's Standards (the Ten Standards for Rehabilitation) and makes recommendations to both the DED (for state applications) and the NPS (for federal applications).