Bradley Myers (North Dakota) has published The Low-Income Housing Tax Credit: A Proposal to Address Concerns Regarding Non-Profit / For-Profit Partnerships, 60 Tax Law. 415 (2007). Here is part of the Introduction:

This Article proposes a change to the structure of LIHTC transactions which should satisfy the concerns of the Service that nonprofits maintain control over housing projects, while at the same time satisfying investors that their money is not at any greater risk. An assumption of this Article is that participation of nonprofits in the development and ownership of property is to be greatly encouraged.11 Part II of this Article discusses the history of the development of the control standard for assessment of nonprofit participation in joint ventures. Part III summarizes and describes the LIHTC and the syndication system that serves as the primary vehicle for use of the credits. Part IV reviews the history of Service treatment of nonprofits involved in low-income housing development using the LIHTC. Finally, Part V discusses a proposal to separate use of the LIHTC and, significantly, the losses generated by the operation of the projects, from ownership of those projects.