To amend the Internal Revenue Code of 1986 to make permanent and expand the temporary minimum credit rate for the low-income housing tax credit program.

Proposals impacting the low-income housing credit, including S. 1442, Improving the Low Income Housing Tax Credit Rate Act, Rep. Camp's tax reform discussion draft, S. 2260 EXPIRE Act, and H.R. 4717, to make permanent the minimum credit rate for the low-income housing tax credit. H.R. 5082, National Disaster Tax Relief Act. H.R. 5771, Tax Increase Prevention Act.

Client expense: Not reported · Firm income: $30,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to Low Income Housing Tax Credit extension (H.R. 4717 and S. 1442).

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S.1442/H.R.4717, Improving the Low Income Housing Tax Credit Rate Act. Support. Support/find a solution for the rehabilitation and repairs of older PRAC 202 properties.

Client expense: Not reported · Firm income: $6,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S.2723: Housing for Homeless Students Act of 2014. A bill to amend the Internal Revenue Code of 1986 to qualify homeless youth and veterans who are full-time students for purposes of the low income housing tax credit; all provisions. S. 1442: Improving the Low-Income Housing Tax Credit Rate Act. A bill to amend the Internal Revenue Code of 1986 to make permanent the minimum low-income housing tax credit rate for unsubsidized buildings and to provide a minimum 4 percent credit rate for existing buildings; all provisions. H.R.4717: To amend the Internal Revenue Code of 1986 to make permanent and expand the temporary minimum credit rate for the low-income housing tax credit program; all provisions. S.2260: Expiring Provisions Improvement, Reform, and Efficiency (EXPIRE) Act of 2014. TITLE I, Subtitle B, Sec. 112-Extension and modification of temporary minimum low-income housing tax credit rate for non-federally subsidized buildings; all provisions. H.R. 5771: Tax Increase Prevention Act of 2014. Division A Title 1 Sec. 112. Extension of temporary minimum low-income housing tax credit rate for non-federally subsidized buildings; all provisions. Draft bill from Rep. David Camp, "Tax Reform Act of 2014" to amend the Internal Revenue Code of 1986 to provide for comprehensive tax reform. TITLE III, all provisions of Section 3204 Low-Income Housing Tax Credit. [not introduced during reporting period.] IRS Notice 2014-18, "Public Comment Invited on Recommendations for 2014-2015 Priority Guidance Plan," [Docket ID: IRS-2014-0011], March 21, 2014; all provisions. [Urged action on the Utility Allowances Submetering Proposed Rule and Casualty Loss Policies.] IRS [RIN 1545-B191] Proposed Rule "Utility Allowances Submetering," August 7, 2012; all provisions.

25C, 45L, Low Income Housing Tax Credit, H.R. 1, carried interest, tax reform, mortgage interest deduction, 179D, H.R. 4717: To amend the Internal Revenue Code of 1986 to make permanent and expand the temporary minimum credit rate for the low-income housing tax credit program, S. 1442: Improving the Low Income Housing Tax Credit Rate Act.

Client expense: $560,000 · Firm income: Not reported

Tax Reform Promoted comprehensive approach to tax reform that avoids enacting reform for C corporations at the expense of flow-through entities. Support maintaining current law regarding: (1) the tax treatment of carried interest; (2) the full deductibility of business interest; (3) the Low-Income Housing Tax Credit and tax-exempt private activity housing bonds; (4) the permanent estate tax rules enacted in January 2013; (5) Section 1031 like-kind exchanges; (6) the 27.5-year depreciation period for multifamily buildings; (7) depreciation recapture; and (8) the deductibility of state and local real estate taxes. Finally, we favor: (1) loosening FIRPTA rules to incent foreign investment in U.S. real estate; and (2) expanding incentives for energy efficiency in commercial buildings (i.e., Internal Revenue Code Section 179D). House Ways and Means and Committee Chairman's Discussion Draft on Tax Reform: Tax Reform Act of 2014. Section 1001: Simplification of individual income tax rates. Section 1002: Deduction for adjusted net capital gain. Section 1405: Repeal of deduction for taxes not paid or accrued in a trade or business. Section 1502: Determination of net earnings from self employment. Section 3104: Reform of accelerated cost recovery system. Section 3113: Repeal of deduction for energy efficient commercial buildings. Section 3133: Repeal of like-kind exchanges. Section 3139: Depreciation recapture on gain from disposition of certain depreciable realty. Section 3204: Low-income housing tax credit. Section 3217: Repeal of new energy efficient home credit. Section 3431: Termination of private activity bonds. Section 3621: Ordinary income treatment in the case of partnership interest held in connection with performance of services. Senate Committee on Finance Chairman's Staff Discussion Draft on Provisions to Reform International Business Taxation. Section 93: Modification to Tax on Foreign Investments in United States Real Property Interests. Senate Committee on Finance Chairman's Staff Discussion Draft to Reform Certain Business Provisions. Section 2: Repeal of Certain Specialized Expensing Provisions (i.e., Section 179D). Section 11: Pooled Asset Cost Recovery System and Depreciation of Real Property. Section 12: Rules Related to Treatment of Gains from Depreciable Property. Section 15: Repeal of Like-Kind Exchanges. Obama Administration's Fiscal Year 2015 Budget Revenue Proposal to Modify Like-Kind Exchange Rules for Real Property. Expiring Tax Provisions S. 2260, Expiring Provisions Improvement Reform and Efficiency (EXPIRE) Act. Section 112: Extension and modification of temporary minimum low-income housing tax credit rate for non-Federally subsidized new buildings. Section 113: Extension of military housing allowance for determining area median gross income. Section 115: Extension and modification of New Markets Tax Credit. Section 125: Extension of Bonus Depreciation. Section 127: Extension and modification of increased expensing limitations and treatment of certain real property as section 179 property. Section 157: Extension of Credit for Energy Efficient New Homes. Section 159: Extension and modification of Energy Efficient Commercial Buildings deduction. H.R. 4457, America's Small Business Tax Relief Act of 2014. Section 2: Expensing certain depreciable assets for small business. H.R.4718, to amend the Internal Revenue Code of 1986 to modify and make permanent bonus depreciation, all provisions. Carried Interest S. 268, Cut Unjustified Tax Loopholes Act, Title VI, Ending the Carried Interest Loophole (Section 601: Short Title. Section 602: Partnership Interests Transferred in Connection with Performance of Services. Section 603: Special rules for Partners Providing Investment Management Services to Partnerships Low-Income Housing Tax Credit (LIHTC) H.R. 4717, to make permanent and expand the minimum rate for the LIHTC, all provisions. S. 1442, Improving the Low Income Housing Tax Credit Rate Act, to amend the Internal Revenue Code of 1986 to make permanent the minimum low-income housing tax credit rate for unsubsidized buildings and to provide a minimum 4 percent credit rate for existing buildings, all provisions. We also (1) support making the LIHTC more flexible by allowing developments to qualify if 40 percent of units go to families with incomes that average no more than 60 percent of area median income; and (2) considered proposals to expand the credit, such ones to increase the program by 50% or convert private activity bonds into Low-Income Housing Tax Credits. Energy Tax Incentives S. 2189, the Energy Efficiency Tax Incentives Act. Section 101: Extension and modification of deduction for energy-efficient commercial buildings. Section 102. Deduction for retrofits of existing commercial and multifamily buildings. S. 2388, Energy-Efficient Cool Roofs Act, to modify the depreciation period for energy-efficient cool roofs, all provisions. H.R. 4740, Roofing Efficiency Jobs Act of 2014, to modify the depreciation period for energy-efficient cool roof systems, all provisions. Foreign Investment in Real Property Tax Act (FIRPTA) H.R. 2870, to amend the Internal Revenue Code to exempt certain stock of real estate investment trusts from the tax on foreign investments in United States real property, all provisions. S. 1181, to amend the Internal Revenue Code to exempt certain stock of real estate investment trusts from the tax on foreign investments in United States real property, all provisions. Draft legislation before the Senate Finance Committee: Preserving America's Transit and Highways Act of 2014, provisions regarding mortgage reporting and FIRPTA. Treasury Regulations REG-119305-11: This document contains proposed regulations under section 707 of the Internal Revenue Code relating to disguised sales of property to, or by, a partnership and under section 752 relating to the treatment of partnership liabilities.

Tax Reform Promoted comprehensive approach to tax reform that avoids enacting reform for C corporations at the expense of flow-through entities. Support maintaining current law regarding: (1) the tax treatment of carried interest; (2) the full deductibility of business interest; (3) the Low-Income Housing Tax Credit and tax-exempt private activity housing bonds; (4) the permanent estate tax rules enacted in January 2013; (5) Section 1031 like-kind exchanges; (7) the 27.5-year depreciation period for multifamily buildings; (7) depreciation recapture; and (8) the deductibility of state and local real estate taxes. Finally, we favor: (1) loosening FIRPTA rules to incent foreign investment in U.S. real estate and (2) expanding incentives for energy efficiency in commercial buildings (i.e., Internal Revenue Code Section 179D). House Ways and Means and Committee Chairman's Discussion Draft on Tax Reform: Tax Reform Act of 2014. Section 1001: Simplification of individual income tax rates. Section 1002: Deduction for adjusted net capital gain. Section 1405: Repeal of deduction for taxes not paid or accrued in a trade or business. Section 1502: Determination of net earnings from self employment. Section 3104: Reform of accelerated cost recovery system. Section 3113: Repeal of deduction for energy efficient commercial buildings. Section 3133: Repeal of like-kind exchanges. Section 3139: Depreciation recapture on gain from disposition of certain depreciable realty. Section 3204: Low-income housing tax credit. Section 3217: Repeal of new energy efficient home credit. Section 3431: Termination of private activity bonds. Section 3621: Ordinary income treatment in the case of partnership interest held in connection with performance of services. Senate Committee on Finance Chairman's Staff Discussion Draft on Provisions to Reform International Business Taxation. Section 93: Modification to Tax on Foreign Investments in United States Real Property Interests. Senate Committee on Finance Chairman's Staff Discussion Draft to Reform Certain Business Provisions. Section 2: Repeal of Certain Specialized Expensing Provisions (i.e., Section 179D). Section 11: Pooled Asset Cost Recovery System and Depreciation of Real Property. Section 12: Rules Related to Treatment of Gains from Depreciable Property. Section 15: Repeal of Like-Kind Exchanges. Expiring Tax Provisions S. 2260, Expiring Provisions Improvement Reform and Efficiency (EXPIRE) Act. Section 112: Extension and modification of temporary minimum low-income housing tax credit rate for non-Federally subsidized new buildings. Section 113: Extension of military housing allowance for determining area median gross income. Section 115: Extension and modification of New Markets Tax Credit. Section 125: Extension of Bonus Depreciation. Section 127: Extension and modification of increased expensing limitations and treatment of certain real property as section 179 property. Section 157: Extension of Credit for Energy Efficient New Homes. Section 159: Extension and modification of Energy Efficient Commercial Buildings deduction. S. Amdt. 3060 to H.R. 3474, Expiring Provisions Improvement, Reform, and Efficiency (EXPIRE) Act of 2014. Section 112: Extension and modification of temporary minimum low-income housing tax credit rate for non-Federally subsidized new buildings. Section 113: Extension of military housing allowance for determining area median gross income. Section 115: Extension and modification of New Markets Tax Credit. Section 125: Extension of Bonus Depreciation. Section 127: Extension and modification of increased expensing limitations and treatment of certain real property as section 179 property. Section 157: Extension of Credit for Energy Efficient New Homes. Section 159: Extension and modification of Energy Efficient Commercial Buildings deduction. H.R. 4457, America's Small Business Tax Relief Act of 2014. Section 2: Expensing certain depreciable assets for small business. H.R.4718, to amend the Internal Revenue Code of 1986 to modify and make permanent bonus depreciation, all provisions. Carried Interest S. 268, Cut Unjustified Tax Loopholes Act, Title VI, Ending the Carried Interest Loophole (Section 601: Short Title. Section 602: Partnership Interests Transferred in Connection with Performance of Services. Section 603: Special rules for Partners Providing Investment Management Services to Partnerships Low-Income Housing Tax Credit & Renter Tax Credit H.R. 4479, to amend the Internal Revenue Code of 1986 to provide a renter's tax credit, all provisions. H.R. 4717, to make permanent and expand the minimum rate for the LIHTC, all provisions. S. 1442, Improving the Low Income Housing Tax Credit Rate Act, to amend the Internal Revenue Code of 1986 to make permanent the minimum low-income housing tax credit rate for unsubsidized buildings and to provide a minimum 4 percent credit rate for existing buildings, all provisions. We also (1) support making the LIHTC more flexible by allowing developments to qualify if 40 percent of units go to families with incomes that average no more than 60 percent of area median income; and (2) considered proposals to expand the credit, such ones to increase the program by 50% or convert private activity bonds into Low-Income Housing Tax Credits. Energy Tax Incentives S. 2189, the Energy Efficiency Tax Incentives Act. Section 101: Extension and modification of deduction for energy-efficient commercial buildings. Section 102. Deduction for retrofits of existing commercial and multifamily buildings. FIRPTA H.R. 2870, to amend the Internal Revenue Code to exempt certain stock of real estate investment trusts from the tax on foreign investments in United States real property, all provisions. S. 1181, to amend the Internal Revenue Code to exempt certain stock of real estate investment trusts from the tax on foreign investments in United States real property, all provisions. Draft legislation before the Senate Finance Committee: Preserving America's Transit and Highways Act of 2014, provisions regarding mortgage reporting and FIRPTA Treasury Regulations REG-119305-11: This document contains proposed regulations under section 707 of the Internal Revenue Code (Code) relating to disguised sales of property to, or by a partnership and under section 752 relating to the treatment of partnership liabilities.

25C, 45L, Low Income Housing Tax Credit, H.R. 1, carried interest, tax reform, mortgage interest deduction, 179D, H.R. 4717: To amend the Internal Revenue Code of 1986 to make permanent and expand the temporary minimum credit rate for the low-income housing tax credit program, S. 1442: Improving the Low Income Housing Tax Credit Rate Act.

Client expense: $610,000 · Firm income: Not reported

Issues related to Low Income Housing Tax Credit extension (H.R. 4717 and S. 1442).

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S.1442/H.R.4717, Improving the Low Income Housing Tax Credit Rate Act. Support. Support to find a solution for the rehabilitation and repairs of older PRAC 202 properties.

Client expense: Not reported · Firm income: $6,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Proposals impacting the low-income housing credit, including S. 1442, Improving the Low Income Housing Tax Credit Rate Act, Rep. Camp's tax reform discussion draft, S. 2260 EXPIRE Act, and H.R. 4717, to make permanent the minimum credit rate for the low-income housing tax credit. H.R. 5082, National Disaster Tax Relief Act.

Client expense: Not reported · Firm income: $40,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Budget of the United States Government, Fiscal Year 2015; all provisions relating to the U.S. Department of Housing and Urban Development (HUD), U.S. Department of Agriculture (USDA) -Rural Housing Service (RHS) funding and administration of affordable multifamily housing and rental assistance programs and Treasury-Internal Revenue Service (IRS) proposals related to the Low Income Housing Tax Credit (LIHTC) and bond-financed multifamily housing programs. (Continued).H.R. 4800: Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2015. Making appropriations for Agriculture, Rural Development, Food and Drug Administration, and Related Agencies programs for the fiscal year ending September 30, 2015, and for other purposes. TITLE III RURAL DEVELOPMENT PROGRAMS - all provisions under Rural Housing Service related to affordable multifamily housing programs. S. 2389: Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2015. An original bill making appropriations for Agriculture, Rural Development, Food and Drug Administration, and Related Agencies programs for the fiscal year ending September 30, 2015, and for other purposes. TITLE III -RURAL DEVELOPMENT PROGRAMS - all provisions under Rural Housing Service related to affordable multifamily housing & rental assistance programs. H.R.4745: Transportation, Housing and Urban Development, and Related Agencies Appropriations Act, 2015. Making appropriations for the Departments of Transportation, and Housing and Urban Development, and related agencies for the fiscal year ending September 30, 2015, and for other purposes. TITLE II DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT - all provisions related to affordable multifamily housing & rental assistance programs. House Report 113-464 - DEPARTMENTS OF TRANSPORTATION, AND HOUSING AND URBAN DEVELOPMENT, AND RELATED AGENCIES APPROPRIATIONS BILL, 2015: Title II--Department of Housing and Urban Development, all provisions related to funding and administration of the project-based Section 8 program, the Section 8 performance-based contract administration program and HUD's Initiative "Transforming Multifamily for the 21st Century" plan for reorganization of its multifamily offices and field structure. S. 2438: Transportation, Housing and Urban Development, and Related Agencies Appropriations Act, 2015. An original bill making appropriations for the Departments of Transportation, and Housing and Urban Development, and related agencies for the fiscal year ending September 30, 2015, and for other purposes. TITLE II DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT - all provisions related to affordable multifamily housing & rental assistance programs. Senate Report 113-182 - TRANSPORTATION AND HOUSING AND URBAN DEVELOPMENT, AND RELATED AGENCIES APPROPRIATIONS BILL, 2015: TITLE II DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT, all provisions related to funding and administration of the project-based Section 8 program, the Section 8 performance-based contract administration program and HUD's Initiative "Transforming Multifamily for the 21st Century" plan for reorganization of its multifamily offices and field structure. Budget of the United States Government, Fiscal Year 2016; all provisions relating to the U.S. Department of Housing and Urban Development (HUD) project-based Section 8 program. (not introduced during reporting period.) Transportation, Housing and Urban Development, and Related Agencies Appropriations Act, 2016; all provisions related to project-based Section 8 program. (not introduced during reporting period.) H.R. 4146: Preservation, Enhancement and Savings Opportunity Act of 2014. A bill to amend the Low-Income Housing Preservation and Resident Homeownership Act of 1990; all provisions. S. 1442: Improving the Low-Income Housing Tax Credit Rate Act. A bill to amend the Internal Revenue Code of 1986 to make permanent the minimum low-income housing tax credit rate for unsubsidized buildings and to provide a minimum 4 percent credit rate for existing buildings; all provisions. H.R.4717 - To amend the Internal Revenue Code of 1986 to make permanent and expand the temporary minimum credit rate for the low-income housing tax credit program; all provisions.S.2260 - Expiring Provisions Improvement, Reform, and Efficiency (EXPIRE) Act of 2014:A bill to amend the Internal Revenue Code of 1986 to extend certain expiring provisions, and for other purposes: TITLE I, Subtitle B, Sec. 112. Extension and modification of temporary minimum low-income housing tax credit rate for non-federally subsidized buildings; all provisions. Draft bill from Rep. David Camp, "Tax Reform Act of 2014" to amend the Internal Revenue Code of 1986 to provide for comprehensive tax reform. TITLE IIIBUSINESS TAX REFORM; all provisions of Section 3204 Low-Income Housing Tax Credit. [not introduced during reporting period.] S.2723 - Housing for Homeless Students Act of 2014. A bill to amend the Internal Revenue Code of 1986 to qualify homeless youth and veterans who are full-time students for purposes of the low income housing tax credit; all provisions. S.1217 - Housing Finance Reform and Taxpayer Protection Act of 2013: A bill to provide secondary mortgage market reform, and for other purposes; all provisions. H.R.2767 - Protecting American Taxpayers and Homeowners (PATH) Act of 2013: A bill to protect American taxpayers and homeowners by creating a sustainable housing finance system for the 21st century; all provisions. H.R. 5055 - Partnership to Strengthen Homeownership Act of 2014; A bill to reform the housing finance system of the United States, and for other purposes; all provisions. Adovacted for Section 8 and Rental Assistance Reform consistent with the April 13, 2012 House Financial Services Committee Discussion Draft Legislation, Affordable Housing and Self-Sufficiency Improvement Act of 2012: A bill to reform affordable housing programs and the provision of supportive services under the United States Housing Act of 1937; all provisions [not introduced during reporting period]. Offered preliminary policy recommendations that would achieve cost savings in the management & operation of federally assisted multifamily housing by: Eliminating Costs Unique to Affordable Housing; Performing Income Certifications Once for All Programs; Using Federal Tax Returns for Rent Calculations; Track, Enforce and Prevent Repeat Payment Agreements; Reduce the frequency of Management Occupancy Reviews (MORs); and examine the feasiblity of reducing or eliminating interim income recertifications. The White House Domestic Policy Council Rental Policy Working Groups "Federal Rental Alignment-Administrative Proposals, December 31, 2011; all provisions (to better align the operation of federal rental programs and policies across the Administration) with specific emphasis on the Physical Inspection Pilot Program (for mixed-financed properties). Federal Housing Finance Agency, "The 2014 Strategic Plan for the Conservatorships of Fannie Mae and Freddie Mac," May 13, 2014; all provisions which affect GSE's multifamily portfolios and operations during conservatorship. All policies, funding and administrative issues related to management, production & preservation of affordable multifamily housing subject to HUD, USDA-RHS, and Treasury-IRS regulations. HUD Final Rule, "The Housing and Economic Recovery Act of 2008 (HERA): Changes to the Section 8 Tenant-Based Voucher and Section 8 Project-Based Voucher Programs,"[Docket No. FR5242F02] June 25, 2014; all provisions. HUD Notice H 2012-5, "Guidelines on Addressing Infestations in HUD-insured and Assisted Multifamily Housing," April 23, 2012; all provisions.HUD Notice [Docket No. FR5720N01] "The Violence Against Women Reauthorization Act of 2013: Overview of Applicability to HUD Programs," August 6, 2013; all provisions. HUD's "Affirmative Fair Housing Marketing Plan (AFHMP)-Multifamily Housing" Form HUD-935.2A (12/2011); all provisions. Title 24 CFR Part 200, Subpart M-Affirmative Fair Housing Marketing Regulations; all provisions of this HUD regulation for Affirmative Fair Housing Marketing requirements in HUD's Federal Housing Administration (FHA) multifamily housing programs. Title 24 CFR Part 8, Subpart CProgram Accessibility; all provisions of this HUD regulation which require nondiscrimination based on Handicap in HUD's FHA multifamily assisted properties with emphasis on 8.22 New constructionhousing facilities, 8.23 Alterations of existing housing facilities, 8.32 Accessibility standards and 8.33 Housing adjustments. Title 24 CFR Part 100, Subpart D - Prohibition Against Discrimination Because of Handicap; all provisions of this HUD Regulation with emphasis on requirements for rental properties in 100.203 Reasonable modifications of existing premises, 100.204 Reasonable accommodations, and 100.205 Design and construction requirements. HUD Initiative "Transforming Multifamily for the 21st Century"; all provisions. HUD Report "Multifamily Housing Transformation," 2014; all provisions. HUD "Performance-Based Annual Contributions Contract, Project-Based Section 8 Contract Administration," February 24, 2012; all provisions. HUD [Docket No. FR-5600-N-33-C1] "HUDs Fiscal Year (FY) 2011 NOFA for the Performance-Based Contract Administrator (PBCA) Program Technical Correction," March 15, 2012; all provisions. HUD [Docket No. FR-5600-N-33] "HUDs Fiscal Year (FY) 2012 Notice of Funding Availability (NOFA) for the Performance-Based Contract Administrator (PBCA) Program for the Administration of Project-Based Section 8 Housing Assistance Payments Contracts," March 9, 2012; all provisions. HUD "Annual Contributions Contract Project-Based Section 8 Contract Administration, Second Amendment of Term, Incentive- Based Performance Standards Tasks, and Fees " October 17, 2012; all provisions. Urged amending to include Management & Occupancy Reviews (MORs) in PBCA tasks [not included]. HUD "Revised Section 8 Renewal Policy Guide for Public Comment," February 28, 2014; all provisions, especially Chapter 9, Section 9-23 Special Procedures When An RCS [Rent Comparability Study] Shows That A Projects Median Market Rent Exceeds 110 Percent Ofthe Median Gross Rent For The Projects Zip Code. HUD [Docket No. FR5413N02] "Section 8 Housing Choice Voucher ProgramDemonstration Project of Small Area Fair Market Rents in Certain Metropolitan Areas, Discussion of Comments, and Request for Participation," April 20, 2011; all provisions. HUD Notice of "Proposed Fair Market Rents for the Housing Choice Voucher Program, Moderate Rehabilitation Single Room Occupancy Program and Other Programs Fiscal Year 2015" [Docket No. FR5807N01]; August 15, 2014; all provisions. HUD Handbook 4350.1 REV-2, Multifamily Asset Management and Project Servicing; all provisions. Re-write of HUD Handbook 4350.1 Multifamily Housing Asset Management & Servicing draft "Chapter 11.1 Multifamily Emergency Disaster Assistance;" all provisions. Re-write of HUD Handbook 4350.1 Multifamily Housing Asset Management & Servicing draft "Chapter 12.9 Prepayment of Section 202 Loans" all provisions.Re-write of HUD Handbook 4350.1 Multifamily Housing Asset Management & Servicing draft "Guide to Units, Chapters, Section Headings & Subheadings;" all provisions. Re-write of HUD Handbook 4350.1 Multifamily Housing Asset Management & Servicing draft "Chapter 3.7 Preventing Defaults and Assignments;" all provisions. Re-write of HUD Handbook 4350.1 Multifamily Housing Asset Management & Servicing draft "Chapter 12.10 Tax Credits and Subsidy Layering;" all provisions. Re-write of HUD Handbook 4350.1 Multifamily Housing Asset Management & Servicing draft "Chapter 3.4 Insurance and Loss Drafts;" all provisions. Re-write of HUD Handbook 4350.1 Multifamily Housing Asset Management & Servicing draft "Chapter 9.1 Transfers of Physical Assets;" all provisions. HUD Handbook 4350.3 REV-1: Occupancy Requirements of Subsidized Multifamily Housing Programs, November 2013; all provisions. HUD's Tenant Rental Assistance Certification System (TRACS) Release 2.0.2.(d); all provisions and policies concerning collection of repayment agreement information between tenants and assisted property owners. All policies related to HUD's: Real Estate Assesment Center scoring and procedures for HUD-assisted and/or FHA insured properties; 2530 previous participation certification policies and submission procedures; Management and Occupancy Review for owners and management agents, "Workload Sharing" pilot programs, "Sustaining our Investments" Initiative and service coordinator program. IRS Notice 2014-18, "Public Comment Invited on Recommendations for 2014-2015 Priority Guidance Plan," [Docket ID: IRS-2014-0011], March 21, 2014; all provisions. [Urged action on the Utility Allowances Submetering Proposed Rule and Casualty Loss Policies.] IRS [RIN 1545-B191] Proposed Rule "Utility Allowances Submetering," August 7, 2012; all provisions. USDA-RHS Unnumbered Letter "Underwriting Guidance for Transfer and [Multi-Family Housing Preservation & Revitalization]MPR Multi-Family Housing Transactions," September 30, 2013; all provisions. USDA-Rural Development Procedure Notice 472, September 29, 2014; all provisions of INSERT RD HB-2-3560 MFH ASSET MANAGEMENT HANDBOOK Chapter 3 Attachment 3-F (RD Handbook Changes, Revision to HB-2-3650 Attachment 3-F to reflect increases in Fiscal Year 2015 Management Fees). USDA- Rural Development Administrative Notice RD AN No. 4747 (1944-N) "Implementation of 42 U.S.C. 14043e-11 of the Violence Against Women Reauthorization Act in Rural Developments Multi-Family Housing Programs," February 10, 2014; all provisions. Advocated for policies to address ongoing occupancy issues, including prolonged vacancies, in properties that participate in USDA-RHS's Multifamily Housing programs. Advocated for policies to address improper payments in USDA-RHS's Section 521 Rural Rental Assistance program, including access to HUD's Enterprise Income Verification system. All policies related to USDA Rural Development's Improper Payments Information Act (IPIA) audit for the Rental Assistance Program, Multi-Family Integrated System and its findings reviews, and rural housing preservation.

Tax Reform Promoted comprehensive approach to tax reform that avoids enacting reform for C corporations at the expense of flow-through entities. Support maintaining current law regarding: (1) the tax treatment of carried interest; (2) the full deductibility of business interest; (3) the Low-Income Housing Tax Credit and tax-exempt private activity housing bonds;(4) the permanent estate tax rules enacted in January 2013; (5) Section 1031 like-kind exchanges; (7) the 27.5-year depreciation period for multifamily buildings; (7) depreciation recapture; and (8) the deductibility of state and local real estate taxes. Finally, we favor: (1) loosening FIRPTA rules to incent foreign investment in U.S. real estate and (2) expanding incentives for energy efficiency in commercial buildings (i.e., Internal Revenue Code Section 179D). House Ways and Means and Committee Chairman's Discussion Draft on Tax Reform: Tax Reform Act of 2014. Section 1001: Simplification of individual income tax rates. Section 1002: Deduction for adjusted net capital gain. Section 1405: Repeal of deduction for taxes not paid or accrued in a trade or business. Section 1502: Determination of net earnings from self employment. Section 3104: Reform of accelerated cost recovery system. Section 3113: Repeal of deduction for energy efficient commercial buildings. Section 3133: Repeal of like-kind exchanges. Section 3139: Depreciation recapture on gain from disposition of certain depreciable realty. Section 3204: Low-income housing tax credit. Section 3217: Repeal of new energy efficient home credit. Section 3431: Termination of private activity bonds. Section 3621: Ordinary income treatment in the case of partnership interest held in connection with performance of services. Senate Committee on Finance Chairman's Staff Discussion Draft on Provisions to Reform International Business Taxation. Section 93: Modification to Tax on Foreign Investments in United States Real Property Interests. Senate Committee on Finance Chairman's Staff Discussion Draft to Reform Certain Business Provisions. Section 2: Repeal of Certain Specialized Expensing Provisions (i.e., Section 179D). Section 11: Pooled Asset Cost Recovery System and Depreciation of Real Property. Section 12: Rules Related to Treatment of Gains from Depreciable Property. Section 15: Repeal of Like-Kind Exchanges. Expiring Tax Provisions S. 2260, Expiring Provisions Improvement Reform and Efficiency (EXPIRE) Act. Section 112: Extension and modification of temporary minimum low-income housing tax credit rate for non-Federally subsidized new buildings. Section 113: Extension of military housing allowance for determining area median gross income. Section 115: Extension and modification of New Markets Tax Credit. Section 125: Extension of Bonus Depreciation. Section 127: Extension and modification of increased expensing limitations and treatment of certain real property as section 179 property. Section 157: Extension of Credit for Energy Efficient New Homes. Section 159: Extension and modification of Energy Efficient Commercial Buildings deduction. S. Amdt. 3060 to H.R. 3474, Expiring Provisions Improvement, Reform, and Efficiency (EXPIRE) Act of 2014. Section 112: Extension and modification of temporary minimum low-income housing tax credit rate for non-Federally subsidized new buildings. Section 113: Extension of military housing allowance for determining area median gross income. Section 115: Extension and modification of New Markets Tax Credit. Section 125: Extension of Bonus Depreciation. Section 127: Extension and modification of increased expensing limitations and treatment of certain real property as section 179 property. Section 157: Extension of Credit for Energy Efficient New Homes. Section 159: Extension and modification of Energy Efficient Commercial Buildings deduction. H.R. 4457, America's Small Business Tax Relief Act of 2014. Section 2: Expensing certain depreciable assets for small business. H.R.4718, to amend the Internal Revenue Code of 1986 to modify and make permanent bonus depreciation, all provisions.Carried Interest S. 268, Cut Unjustified Tax Loopholes Act, Title VI, Ending the Carried Interest Loophole (Section 601: Short Title. Section 602: Partnership Interests Transferred in Connection with Performance of Services. Section 603: Special rules for Partners Providing Investment Management Services to Partnerships Low-Income Housing Tax Credit & Renter Tax Credit H.R. 4479, to amend the Internal Revenue Code of 1986 to provide a renter's tax credit, all provisions. H.R. 4717, to make permanent and expand the minimum rate for the LIHTC, all provisions. S. 1442, Improving the Low Income Housing Tax Credit Rate Act, to amend the Internal Revenue Code of 1986 to make permanent the minimum low-income housing tax credit rate for unsubsidized buildings and to provide a minimum 4 percent credit rate for existing buildings, all provisions. We also (1) support making the LIHTC more flexible by allowing developments to qualify if 40 percent of units go to families with incomes that average no more than 60 percent of area median income; and (2) considered proposals to expand the credit, such ones to increase the program by 50% or convert private activity bonds into Low-Income Housing Tax Credits. Energy Tax Incentives S. 2189, the Energy Efficiency Tax Incentives Act. Section 101: Extension and modification of deduction for energy-efficient commercial buildings. Section 102. Deduction for retrofits of existing commercial and multifamily buildings. FIRPTA H.R. 2870, to amend the Internal Revenue Code to exempt certain stock of real estate investment trusts from the tax on foreign investments in United States real property, all provisions. S. 1181, to amend the Internal Revenue Code to exempt certain stock of real estate investment trusts from the tax on foreign investments in United States real property, all provisions. Draft legislation before the Senate Finance Committee: Preserving America's Transit and Highways Act of 2014, provisions regarding mortgage reporting and FIRPTA Treasury Regulations REG-119305-11: This document contains proposed regulations under section 707 of the Internal Revenue Code (Code) relating to disguised sales of property to, or by a partnership and under section 752 relating to the treatment of partnership liabilities.

Issues related to Low Income Housing Tax Credit extension (H.R. 4717 and S.1442).

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Proposals impacting the low-income housing credit, including S. 1442, Improving the Low Income Housing Tax Credit Rate Act, Rep. Camp's tax reform discussion draft, S. 2260 EXPIRE Act, and H.R. 4717, to make permanent the minimum credit rate for the low-income housing tax credit.

Client expense: Not reported · Firm income: $40,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Budget of the United States Government, Fiscal Year 2015; all provisions relating to the U.S. Department of Housing and Urban Development (HUD), U.S. Department of Agriculture (USDA) -Rural Housing Service (RHS) funding and administration of affordable multifamily housing and rental assistance programs and Treasury-Internal Revenue Service (IRS) proposals related to the Low Income Housing Tax Credit (LIHTC) and bond-financed multifamily housing programs. (Continued).House Report 113-474 - Report on the Revised Suballocation of Budget Allocations for Fiscal Year 2015. June 17, 2014; all provisions related to the 302(b) allocation to the House Appropriations Subcommittee on Transportation, Housing and Urban Development, and Related Agencies (THUD) for fiscal year (FY) 2015. Senate Report 113163: Allocation To Subcommittees of Budget Totals for Fiscal Year 2015. May 22, 2014; all provisions related to the 302(b) allocation to the Senate Appropriations Subcommittee on Transportation, Housing and Urban Development, and Related Agencies (THUD) in fiscal year (FY) 2015. H.R. 4800: Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2015. Making appropriations for Agriculture, Rural Development, Food and Drug Administration, and Related Agencies programs for the fiscal year ending September 30, 2015, and for other purposes. TITLE III RURAL DEVELOPMENT PROGRAMS - all provisions under Rural Housing Service related to affordable multifamily housing programs. S. 2389: Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2015. An original bill making appropriations for Agriculture, Rural Development, Food and Drug Administration, and Related Agencies programs for the fiscal year ending September 30, 2015, and for other purposes. TITLE III -RURAL DEVELOPMENT PROGRAMS - all provisions under Rural Housing Service related to affordable multifamily housing & rental assistance programs. H.R.4745: Transportation, Housing and Urban Development, and Related Agencies Appropriations Act, 2015. Making appropriations for the Departments of Transportation, and Housing and Urban Development, and related agencies for the fiscal year ending September 30, 2015, and for other purposes. TITLE II DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT - all provisions related to affordable multifamily housing & rental assistance programs. H.Amdt.802 (to H.R. 4745 Transportation, Housing and Urban Development, and Related Agencies Appropriations Act, 2015). An amendment to prohibit use of funds to require the relocation, or to carry out any required location, of any asset management positions of the Office of Multifamily Housing of the Department of Housing and Urban Development in existence as of the date of the enactment of this Act; all provisions. House Report 113-464 - DEPARTMENTS OF TRANSPORTATION, AND HOUSING AND URBAN DEVELOPMENT, AND RELATED AGENCIES APPROPRIATIONS BILL, 2015: Title II--Department of Housing and Urban Development, all provisions related to funding and administration of the project-based Section 8 program, the Section 8 performance-based contract administration program and HUD's Initiative "Transforming Multifamily for the 21st Century" plan for reorganization of its multifamily offices and field structure. S. 2438: Transportation, Housing and Urban Development, and Related Agencies Appropriations Act, 2015. An original bill making appropriations for the Departments of Transportation, and Housing and Urban Development, and related agencies for the fiscal year ending September 30, 2015, and for other purposes. TITLE II DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT - all provisions related to affordable multifamily housing & rental assistance programs. Senate Report 113-182 - TRANSPORTATION AND HOUSING AND URBAN DEVELOPMENT, AND RELATED AGENCIES APPROPRIATIONS BILL, 2015: TITLE II DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT, all provisions related to funding and administration of the project-based Section 8 program, the Section 8 performance-based contract administration program and HUD's Initiative "Transforming Multifamily for the 21st Century" plan for reorganization of its multifamily offices and field structure.H.R.4660 - Commerce, Justice, Science, and Related Agencies Appropriations Act, 2015: Making appropriations for the Departments of Commerce and Justice, Science, and Related Agencies for the fiscal year ending September 30, 2015, and for other purposes. TITLE I DEPARTMENT OF COMMERCE, Bureau of the Census, all provisions under Periodic Censuses and Programs related to funding for Census 2020 planning and the American Community Survey (ACS) [residential and commercial real estate entities, as well as lenders rely on accurate Census and robust American Community Survey information]. TITLE V GENERAL PROVISIONS, all provisions of Sec. 545 related to the American Community Survey. H.Amdt.752 (to H.R.4660 Commerce, Justice, Science, and Related Agencies Appropriations Act, 2015):An amendment to prohibit the use of funds to enforce section 221 of title 13, United States Code, with respect to the American Community Survey (ACS); all provisions [which prohibit the Federal Government from enforcing a potential fine against a person for failure to fill out the ACS.] S. 1442: Improving the Low-Income Housing Tax Credit Rate Act. A bill to amend the Internal Revenue Code of 1986 to make permanent the minimum low-income housing tax credit rate for unsubsidized buildings and to provide a minimum 4 percent credit rate for existing buildings; all provisions. H.R.4717 - To amend the Internal Revenue Code of 1986 to make permanent and expand the temporary minimum credit rate for the low-income housing tax credit program; all provisions. S.2260 - Expiring Provisions Improvement, Reform, and Efficiency (EXPIRE) Act of 2014:A bill to amend the Internal Revenue Code of 1986 to extend certain expiring provisions, and for other purposes: TITLE I, Subtitle B, Sec. 112. Extension and modification of temporary minimum low-income housing tax credit rate for non-federally subsidized buildings; all provisions. Draft bill from Rep. David Camp, "Tax Reform Act of 2014" to amend the Internal Revenue Code of 1986 to provide for comprehensive tax reform. TITLE IIIBUSINESS TAX REFORM; all provisions of Section 3204 Low-Income Housing Tax Credit. [not introduced during reporting period.] Draft bill from Sen. Al Franken,"Housing for Homeless Students Act of 2014;" all provisions. [not introduced during reporting period]. S.1217 - Housing Finance Reform and Taxpayer Protection Act of 2013: A bill to provide secondary mortgage market reform, and for other purposes; all provisions. H.R.2767 - Protecting American Taxpayers and Homeowners (PATH) Act of 2013: A bill To protect American taxpayers and homeowners by creating a sustainable housing finance system for the 21st century; all provisions. Adovacted for Section 8 and Rental Assistance Reform consistent with the April 13, 2012 House Financial Services Committee Discussion Draft Legislation, Affordable Housing and Self-Sufficiency Improvement Act of 2012: A bill to reform affordable housing programs and the provision of supportive services under the United States Housing Act of 1937; all provisions [not introduced during reporting period]. Offered preliminary policy recommendations that would achieve cost savings in the management & operation of federally assisted multifamily housing by: Eliminating Costs Unique to Affordable Housing; Performing Income Certifications Once for All Programs; Using Federal Tax Returns for Rent Calculations; Track, Enforce and Prevent Repeat Payment Agreements; Reduce the frequency of Management Occupancy Reviews (MORs); and examine the feasiblity of reducing or eliminating interim income recertifications.Federal Housing Finance Agency, "The 2014 Strategic Plan for the Conservatorships of Fannie Mae and Freddie Mac," May 13, 2014; all provisions which affect GSE's multifamily portfolios and operations during conservatorship. The White House Domestic Policy Council Rental Policy Working Groups "Federal Rental Alignment-Administrative Proposals, December 31, 2011; all provisions (to better align the operation of federal rental programs and policies across the Administration) with specific emphasis on the Physical Inspection Pilot Program (for mixed-financed properties). All policies, funding and administrative issues related to management, production & preservation of affordable multifamily housing subject to HUD, USDA-RHS, and Treasury-IRS regulations. HUD Notice [Docket No FR5728N01] "Small Multifamily Building Risk Share Initiative: Request for Comment," November 4, 2013; all provisions. HUD Notice [Docket No. FR5720N01] "The Violence Against Women Reauthorization Act of 2013: Overview of Applicability to HUD Programs," August 6, 2013; all provisions. HUD's "Affirmative Fair Housing Marketing Plan (AFHMP)-Multifamily Housing" Form HUD-935.2A (12/2011); all provisions. Title 24 CFR Part 200, Subpart M-Affirmative Fair Housing Marketing Regulations; all provisions of this HUD regulation for Affirmative Fair Housing Marketing requirements in HUD's Federal Housing Administration (FHA) multifamily housing programs. Title 24 CFR Part 8, Subpart CProgram Accessibility; all provisions of this HUD regulation which require nondiscrimination based on Handicap in HUD's FHA multifamily assisted properties with emphasis on 8.22 New constructionhousing facilities, 8.23 Alterations of existing housing facilities, 8.32 Accessibility standards and 8.33 Housing adjustments. Title 24 CFR Part 100, Subpart D - Prohibition Against Discrimination Because of Handicap; all provisions of this HUD Regulation with emphasis on requirements for rental properties in 100.203 Reasonable modifications of existing premises, 100.204 Reasonable accommodations, and 100.205 Design and construction requirements. HUD Mortgagee Letter 2012-25, Revised Requirements for Project Capital Needs Assessments, Estimated Reserves for Replacements and Remedies for Accessibility Deficiencies November 21, 2012; all provisions. HUD Notice H 2012-27 Revised Requirements for Project Capital Needs Assessments, Estimated Reserves for Replacements and Remedies for Accessibility Deficiencies November 21, 2012; all provisions. HUD Initiative "Transforming Multifamily for the 21st Century"; all provisions. HUD Report "Multifamily Housing Transformation," 2014; all provisions. HUD Announcement, "Moving Forward with Multifamily Transformation," April 4, 2014; all provisions. HUD Notice H 2012-5, "Guidelines on Addressing Infestations in HUD-insured and Assisted Multifamily Housing," April 23, 2012; all provisions.HUD "Performance-Based Annual Contributions Contract, Project-Based Section 8 Contract Administration," February 24, 2012; all provisions. HUD [Docket No. FR-5600-N-33-C1] "HUDs Fiscal Year (FY) 2011 NOFA for the Performance-Based Contract Administrator (PBCA) Program Technical Correction," March 15, 2012; all provisions. HUD [Docket No. FR-5600-N-33] "HUDs Fiscal Year (FY) 2012 Notice of Funding Availability (NOFA) for the Performance-Based Contract Administrator (PBCA) Program for the Administration of Project-Based Section 8 Housing Assistance Payments Contracts," March 9, 2012; all provisions. HUD "Annual Contributions Contract Project-Based Section 8 Contract Administration, Second Amendment of Term, Incentive- Based Performance Standards Tasks, and Fees " October 17, 2012; all provisions. Urged amending to include Management & Occupancy Reviews (MORs) in PBCA tasks [not included]. Re-write of HUD Handbook 4350.1 Multifamily Housing Asset Management & Servicing draft "Guide to Units, Chapters, Section Headings & Subheadings;" all provisions. Re-write of HUD Handbook 4350.1 Multifamily Housing Asset Management & Servicing draft "Chapter 3.7 Preventing Defaults and Assignments;" all provisions. Re-write of HUD Handbook 4350.1 Multifamily Housing Asset Management & Servicing draft "Chapter 12.10 Tax Credits and Subsidy Layering;" all provisions. Re-write of HUD Handbook 4350.1 Multifamily Housing Asset Management & Servicing draft "Chapter 3.4 Insurance and Loss Drafts;" all provisions. Re-write of HUD Handbook 4350.1 Multifamily Housing Asset Management & Servicing draft "Chapter 9.1 Transfers of Physical Assets;" all provisions. HUD Notice H 2011-30 "Use of Reserve for Replacement Accounts in Restructured Mark-to-Market (M2M) Properties," October 19, 2011; all provisions. HUD Handbook 4350.1 REV-2, Multifamily Asset Management and Project Servicing; all provisions, especially Chapter 4 "Reserve Fund for Replacements." HUD Handbook 4350.3 REV-1: Occupancy Requirements of Subsidized Multifamily Housing Programs, November 2013; all provisions. HUD "Revised Section 8 Renewal Policy Guide for Public Comment," February 28, 2014; all provisions, especially Chapter 9, Section 9-23 Special Procedures When An RCS [Rent Comparability Study] Shows That A Projects Median Market Rent Exceeds 110 Percent Ofthe Median Gross Rent For The Projects Zip Code. HUD [Docket No. FR5413N02] "Section 8 Housing Choice Voucher ProgramDemonstration Project of Small Area Fair Market Rents in Certain Metropolitan Areas, Discussion of Comments, and Request for Participation," April 20, 2011; all provisions. HUD's Tenant Rental Assistance Certification System (TRACS) Release 2.0.2.(d); all provisions and policies concerning collection of repayment agreement information between tenants and assisted property owners.All policies related to HUD's: Real Estate Assesment Center scoring and procedures for HUD-assisted and/or FHA insured properties; 2530 previous participation certification policies and submission procedures; Management and Occupancy Review for owners and management agents, "Workload Sharing" pilot programs, "Sustaining our Investments" Initiative and service coordinator program. IRS "Audit Technique Guide IRC 42, Low-Income Housing Credit" Draft For Comment Only, January 2014; all provisions of Chapter 12 Applicable Fraction concerning deep rent skewing and determining comparable units. IRS Notice 2014-18, "Public Comment Invited on Recommendations for 2014-2015 Priority Guidance Plan," [Docket ID: IRS-2014-0011], March 21, 2014; all provisions. [Urged action on the Utility Allowances Submetering Proposed Rule and Casualty Loss Policies.] IRS [RIN 1545-B191] Proposed Rule "Utility Allowances Submetering," August 7, 2012; all provisions. USDA-RHS [RIN 0575AC93] Proposed Rule, "Civil Monetary Penalties," January 4, 2013; all provisions. USDA-RHS Unnumbered Letter "Underwriting Guidance for Transfer and [Multi-Family Housing Preservation & Revitalization]MPR Multi-Family Housing Transactions," September 30, 2013; all provisions. USDA-Rural Development Procedure Notice 466, December 5, 2013; all provisions of INSERT RD HB-2-3560 MFH ASSET MANAGEMENT HANDBOOK Chapter 3 Attachment 3-F (RD Handbook Changes, Revision to HB-2-3650 Attachment 3-F to reflect no change to Fiscal Year 2014 Management Fee). Advocated for policies to address ongoing occupancy issues, including prolonged vacancies, in properties that participate in USDA-RHS's Multifamily Housing programs. Advocated for policies to address improper payments in USDA-RHS's Section 521 Rural Rental Assistance program, including access to HUD's Enterprise Income Verification system. All policies related to USDA Rural Development's Improper Payments Information Act (IPIA) audit for the Rental Assistance Program, Multi-Family Integrated System and its findings reviews, and rural housing preservation.