Ralph Toye

Ralph Toye advises stakeholders on the investment side of syndicated real estate transactions that qualify for federal low-income housing tax credits (LIHTC), historic rehabilitation tax credits and renewable energy tax credits, helping clients navigate deals financed with complex debt and subsidy structures from a wide variety of public and private sources. Based in Boston, he is a member of Holland & Knight's Tax Credit & Community Development Finance Practice, where he has concentrated his business and tax law work on transactions financed with tax incentives since joining the Firm in 2018.

Affordable housing is a core focus area for Ralph's practice. He has extensive experience with a variety of affordable housing tax credit structures, including low-income multifamily developments, low-income elderly developments, affordable housing preservation and mixed-use developments, as well as developments financed with other housing programs, such as the HOME Investment Partnerships Program, U.S. Department of Housing and Urban Development (HUD) 221(d)(4), 223(f) and 241(a) programs, HUD Section 8 Voucher Program, Community Development Block Grant (CDBG) Program and the HUD 542(b) Risk-Sharing Program. Ralph assists clients with the structuring, negotiation and closing of private placements, proprietary investments and multifund investments, ensuring that these multilayered transactions are structured in a way that will bring about the intended tax benefits while maintaining alignment with the broader business deal.

Ralph also has experience with a broad range of tax credit investment portfolio management, regularly advising clients on matters regarding contract interpretation, negotiations with lenders and governmental agencies in connection with post-closing restructurings and amendments, refinancings and loan workout agreements, and other matters that arise during the life of an affordable housing development.

His earlier experience spans both corporate and public sector settings. During law school, Ralph worked in the legal department of a large utility company, where he handled diligence and corporate compliance matters, and at the Massachusetts Division of Capital Asset Management and Maintenance (DCAMM), where he was involved in the procurement process. That grounding has helped him navigate the mix of public programs and private capital that makes these transactions work.