INDIANA—HUD released the 2025 Multifamily Tax Subsidy Income Limits for the Low-Income Housing Tax Credit Program, effective April 1, 2025. These limits must be implemented within 45 days of this date.
Income and rent limits are no longer based solely on the county in which a development is located. Instead, limits are project-specific, based on the date the project was placed in service. A “project” is defined by the election made by the owner on Form 8609, Part II, Line 8b. If buildings within the same development are considered separate “projects” (i.e., if Line 8b of the 8609 is marked “no”), then each building may potentially have different sets of limits. Even if the multiple building project election is marked yes, it is essential to note that separate phases are considered different projects and are therefore likely to have different limits.
The Housing and Economic Recovery Act of 2008 (HERA) created special limits for projects, which were defined as “HUD hold harmless impacted projects.” A project is eligible to use the HERA special limits if:
1. The county has HERA special limits published, and
2. The project was placed in service on or before December 31, 2008.
Furthermore, HERA established an additional “hold-harmless” policy for all tax credit projects. Under this policy, a project’s income and rent limits will never decrease from one year to the next, even if there is a decrease in the HUD published limits for the county where the project is located. However, a project is never eligible to use a set of limits if it was not placed in service during the time those limits were in effect. A multi-building project is considered placed-in-service on the date the first building in that project is put into service. For more information on correctly applying income and rent limits, please refer to Section 4, Parts 4.1 and 4.2 of IHCDA’s 2024 Rental Housing Tax Credit Compliance Manual.
25-16: QAP – Revision & FAQ
IHCDA has released a minor revision to the 2026-2027 QAP (marked with “v.2” in the footer) along with an FAQ document, both of which can be accessed here.
If you have any questions, please contact Alan Rakowski, Director of Real Estate Allocation, at (317) 233-1220 or arakowski@ihcda.in.gov.
