Form 8874 (Rev. 11-2018)
Section references are to the Internal Revenue Code unless
For the latest information about developments related to Form
8874 and its instructions, such as legislation enacted after they
were published, go to www.irs.gov/Form8874.
The new markets tax credit allocation has been extended for
calendar years through 2019. To find out if the allocation is
extended beyond 2019, go to www.irs.gov/Form8874.
Purpose of Form
Use Form 8874 to claim the new markets credit for qualified
equity investments made in qualified community development
entities (CDEs). This credit is part of the general business credit.
Taxpayers that are not partnerships or S corporations, and
whose only source of this credit is from those pass-through
entities, are not required to complete or file this form. Instead,
they can report this credit directly on Form 3800, Part III, line 1i.
A qualified CDE is a domestic corporation or partnership that
meets the following requirements.
• Its primary mission is serving, or providing investment capital
for, low-income communities or persons.
• It maintains accountability to residents of low-income
communities through their representation on any governing
board or advisory board of the entity.
• It is certified as a qualified CDE by the Community
Development Financial Institutions (CDFI) Fund of the
Department of the Treasury.
Qualified CDEs also include specialized small business
investment companies and community development financial
institutions. See section 45D(c)(2).
Qualified Equity Investment
A qualified equity investment is an interest in a qualified CDE in
the form of stock (other than nonqualified preferred stock) in a
corporation or a capital interest in a partnership that meets all of
the following requirements.
• You acquired the investment solely for cash at its original
issue (or from a taxpayer for whom the investment was a
qualified equity investment). The cash may be from borrowed
funds, including a nonrecourse loan. For details, see Rev. Rul.
2003-20 and Rev. Rul. 2010-17.
• Substantially all (at least 85%) of the cash is used to make
qualified low-income community investments. The 85%
requirement is reduced to 75% for the seventh year of the
7-year credit period.
• The investment was designated as a qualified equity
investment or a non-real estate qualified equity investment by
the CDE on its books and records for purposes of the new
Generally, a qualified CDE can designate an equity investment
as a qualified equity investment or a non-real estate qualified
equity investment only if it applied for and received a new markets
credit allocation and entered into an allocation agreement with the
CDFI Fund before the equity investment was made.
Qualified CDEs must provide taxpayers holding a
qualified equity investment with a completed Form
8874-A when a qualified equity investment is
Exceptions. An equity investment in an entity that otherwise
qualifies as a qualified equity investment or a non-real estate
qualified equity investment is eligible to be designated as a
qualified equity investment if made prior to an allocation
agreement only if the following applies.
• The equity investment was made on or after the date the CDFI
Fund publishes a Notice of Allocation Availability (NOAA) in the
Federal Register, and the designation of the equity investment
as a qualified equity investment is made for a credit allocation
received under an allocation application submitted to the CDFI
Fund under that NOAA. If the entity in which the equity
investment is made does not receive an allocation under that
NOAA, the equity investment will not be eligible to be
designated as a qualified equity investment. For details, see
Regulations sections 1.45D-1(c)(3)(ii)(B) and 1.45D-1(c)(3)(iii).
The maximum amount of equity investments so designated by
the qualified CDE cannot exceed the amount of the allocation it
received from the CDFI Fund. The names and addresses of
qualified CDEs that have received an allocation for each
allocation round and the amount of that allocation are listed on
the CDFI Fund website at www.cdfifund.gov.
Non-Real Estate Qualified Equity Investment
If a qualified equity investment is designated as a non-real
estate qualified equity investment, then the qualified equity
investment may only satisfy the substantially-all requirement if
the CDE makes qualified low-income community investments
that are directly traceable (including investments made through
one or more CDEs) to non-real estate qualified active low-
income community businesses. The proceeds of a non-real
estate qualified equity investment cannot be used for
transactions involving a qualified active low-income community
business that is not a non-real estate qualified active low-
income community business. See Regulations section
1.45D-1(d) for details about qualified low-income community
How To Figure the Credit
A credit generally is allowed to the holder of the qualified equity
investment on each of 7 credit allowance dates. The credit
allowance dates are the date you make the initial investment
and each of the next 6 anniversary dates. The credit is equal to
the qualified equity investment multiplied by 5% (6% for the 4th
through 7th years). However, the credit is not allowed for a
credit allowance date if the investment is not a qualified equity
investment on that date.
Recapture of the Credit
You may have to increase your tax by a credit recapture
amount if at any time within 7 years from the date of the original
issuance of the qualified equity investment:
• The entity ceases to be a qualified CDE,
• Substantially all of the proceeds of the investment cease to
be used to make qualified low-income community investments,
• The investment is redeemed or otherwise cashed out by the
Exception. If a CDE fails to use substantially all of the proceeds
of a qualified equity investment to make qualified low-income
community investments, the CDE may avoid recapture of the
credit if it corrects the failure within 6 months after the date it
becomes aware (or reasonably should have become aware) of
the failure. Only one correction is permitted for each qualified
equity investment during the 7-year credit period.
See section 45D(g) and Regulations section 1.45D-1(e) for
details, including how to figure the credit recapture amount.
Generally, include the credit recapture amount on the line for
recapture taxes on your income tax return for the year in which
the recapture event occurs. For example, the credit recapture