"HUD has gotten more innovative or flexible in trying to make sure that its financing programs work better with a variety of finance programs, including low-income housing tax credit, historic rehabilitation credits and NMTCs," Nesbitt tells GlobeSt.com.

That trend dovetails a similar one in which developers have begun focusing more on NMTCs to raise equity for apartment projects that also have a commercial component, Banghart says. These credits were never intended to drive production of apartments, he explains, which has made combining NMTCs with other forms of finance in multifamily deals tricky—but not impossible.

For example with historic tax credits, a deal typically needs two partnerships: one that is owned by the developer, which holds a fee interest in the property and leases it to the other partnership, and one for the master-tenant partnership, which is owned by the tax credit investor.