Opportunity Zones Transparency, Extension, and Improvement Act

H.R. 1 One Big Beautiful Bill Act" Energy efficiency and clean energy tax incentives, including the E-QUIP Act and Inflation Reduction Act, and regulatory implementation Like-Kind Exchanges (Sec. 1031) Completed contract method of accounting and condominium construction (Section 460(e) Fair Accounting for Condominium Construction Act (HR 4280) FIRPTA reform and Parity for Non-Traded REITS Act Net investment income tax and SECA liability Cost recovery, residential rental property and nonresidential property Low-income housing tax credit and the Affordable Housing Credit Improvement Act (S 1557 and HR 3238) Proposed and final tax regulations under section 897 and 892 (FIRPTA domestically controlled REIT rules) REIT rules, including investments in related parties Retail Revitalization Act of 2023 (HR 3749) Cancellation of Indebtedness income (section 108) (HR 5580, Saving Our Mainstreet American Locations for Leisure and Shopping Act) Capital gains tax rate State and local tax deduction 20% deduction for pass-through business income (section 199A) and tax rules on pass-through income, including Senator Wyden pass-through reform discussion draft Taxing appreciated capital gains at death Opportunity Zone reform, reporting, and deadline extensions (HR 5761, Opportunity Zones Transparency, Extension and Improvement Act) Revitalizing Downtowns Act and tax incentives for property conversions (HR 9002) Taxing unrealized gains annually - Administration's minimum tax proposal and Chairman Wyden proposal TCJA Permanency Act and issues related to extension of TCJA Business interest deductibility and section 163(j) Active loss limitation and section 461(l) S. 2518, Ending Tax Breaks for Massive Sovereign Wealth Funds Act S. 2224, Stop Predatory Investing Act Treasury guidance: partnership basis-shifting transactions SECA limited partner exception under section 1402(a)(13) Tax and revenue provisions in the budget resolution Deductibility of state and local business taxes, including property taxes (Business SALT)

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

Government targets: Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

Tax Cuts and Job Act Permanency & Tax Reconciliation NMHC supports making permanent individual tax rates and the 20 percent qualified business income tax deduction that expire at the end of 2025. NMHC supports making permanent the Estate Tax rules enacted as part of the Tax Cuts and Jobs Act of 2017 (TCJA). In TCJA, Congress, doubled the estate tax exclusion through 2025 while retaining a top tax rate of 40 percent and stepped-up basis rules. H.R. 1, One Big Beautiful Bill Act, to provide for reconciliation pursuant to title II of H. Con. Res. 14, Title IV--Energy and Commerce, Subtitle C--Communications, Part 2--Artificial Intelligence and Information Technology Modernization, Sec. 43201. Artificial Intelligence and Information Technology Modernization Initiative; Title XI--Committee on Ways and Means, "The One, Big, Beautiful Bill, Subtitle A--Make American Workers and Families Thrive Again: Sec. 110001. Extension of Modification of Rates, Sec. 110005. Extension of Deduction for Qualified Business Income and Permanent Enhancement, Sec. 110006. Extension of Increased Estate and Gift Tax Exemption Amounts and Permanent Enhancement, and Sec. 110011. Limitation on Tax Benefit of Itemized Deductions; Subtitle B--Make Rural America and Main Street Grow Again, Part 1--Extension of Tax Cuts and Jobs Act Reforms for Rural America and Main Street, Sec. 111001. Extension of Special Depreciation Allowance for Certain Property and Sec. 111003. Modified Calculation of Adjusted Taxable Income for Purposes of Business Interest Deduction, Part 2--Additional Tax Relief for Rural America and Main Street, Sec. 111002. Renewal and Enhancement of Opportunity Zones, Sec. 111003. Increased Dollar Limitations for Expensing of Certain Depreciable Assets, and Sec. 111109. Modifications to Low-Income Housing Credit, Subtitle C--Make America Win Again, Part 1--Working Families Over Elites, Sec. 112007. Termination of New Energy Efficient Home Credit, Sec. 112008. Restrictions on Clean Electricity Production Credit, Sec. 112009. Restrictions on Clean Electricity Investment Credit, Sec. 112018. Limitation on Individual Deductions for Certain State and Local Taxes, Etc., Sec. 112026. Limitation on Excess Business Losses of Noncorporate Taxpayers, and Sec. 112028 Enforcement of Remedies Against Unfair Foreign Taxes. Amendment in the Nature of a Substitute to Committee Print Providing for Reconciliation, Title XI--Committee on Ways and Means, "The One, Big, Beautiful Bill, Subtitle A--Make American Workers and Families Thrive Again: Sec. 110001. Extension of Modification of Rates, Sec. 110005. Extension of Deduction for Qualified Business Income and Permanent Enhancement, Sec. 110006. Extension of Increased Estate and Gift Tax Exemption Amounts and Permanent Enhancement, and Sec. 110011. Limitation on Tax Benefit of Itemized Deductions; Subtitle B--Make Rural America and Main Street Grow Again, Part 1--Extension of Tax Cuts and Jobs Act Reforms for Rural America and Main Street, Sec. 111001. Extension of Special Depreciation Allowance for Certain Property and Sec. 111003. Modified Calculation of Adjusted Taxable Income for Purposes of Business Interest Deduction, Part 2--Additional Tax Relief for Rural America and Main Street, Sec. 111002. Renewal and Enhancement of Opportunity Zones, Sec. 111003. Increased Dollar Limitations for Expensing of Certain Depreciable Assets, and Sec. 111109. Modifications to Low-Income Housing Credit, Subtitle C--Make America Win Again, Part 1--Working Families Over Elites, Sec. 112007. Termination of New Energy Efficient Home Credit, Sec. 112008. Phase-Out and Restrictions on Clean Electricity Production Credit, Sec. 112009. Phase-Out and Restrictions on Clean Electricity Investment Credit, Sec. 112018. Limitation on Individual Deductions for Certain State and Local Taxes, Etc., and Sec. 112027. Limitation on Excess Business Losses of Noncorporate Taxpayers. S. Amdt. 2630 to H.R. 1, One Big Beautiful Bill Act, to provide for reconciliation pursuant to title II of H. Con. Res. 14, Amendment in the Nature of a Substitute, Title IV--Committee on Commerce, Science, and Transportation, Sec. 40012: Support for Artificial Intelligence Under the Broadband Equity, Access, and Deployment Program; Title VII--Finance, Subtitle A--Tax, Chapter 1--Providing Permanent Tax Relief for Middle-Class Families and Workers, Sec. 70101: Extension and Enhancement of Reduced Rates, Sec. 70105: Extension and Enhancement of Deduction for Qualified Business Income, Sec. 70106: Extension and Enhancement of Increased Estate and Gift Tax Exemption Amounts, and Sec. 70111: Limitation on Tax Benefits of Itemized Deductions; Chapter 3-Establishing Certainty and Competitiveness for American Job Creators, Subchapter A--Permanent U.S. Business Tax Reform and Boosting Domestic Investment, Sec. 70301: Full Expensing for Certain Business Property, Sec 70303: Modification of Limitation on Business Interest, and Sec. 70306: Increased Dollar Limitations for Expensing of Certain Depreciable Business Assets; Chapter 4--Investing in American Families, Communities, and Small Businesses, Subchapter C--Permanent Investments in Community Development, Sec. 70421: Permanent Renewal and Enhancement of Opportunity Zones and Sec 70422: Permanent Enhancement of Low-Income Housing Tax Credit; Chapter 5:--Ending Green New Deal Spending, Promoting America-First Energy, and Other Reforms, Subchapter A--Termination of Green New Deal Subsidies, Sec 70507: Termination of Energy Efficient Commercial Buildings Deduction; Sec. 70508: Termination of New Energy Efficient Home Credit; Sec. 70512: Termination and Restrictions on Clean Electricity Production Credit; and Sec. 70513: Termination and Restrictions on Clean Electricity Investment Credit; Chapter 6--Enhancing Deduction and Income Tax Credit Guardrails, and Other Reforms, Sec. 70601: Modification and Extension of Limitation on Excess Business Losses by Noncorporate Taxpayers. Senate Finance Committee Reconciliation Legislation: Title VII--Finance, Subtitle A--Tax, Chapter 1--Providing Permanent Tax Relief for Middle-Class Families and Workers, Sec. 70101: Extension and Enhancement of Reduced Rates, Sec. 70105: Extension and Enhancement of Deduction for Qualified Business Income, Sec. 70106: Extension and Enhancement of Increased Estate and Gift Tax Exemption Amounts, and Sec. 70111: Limitation on Tax Benefit of Itemized Deductions; Chapter 3--Establishing Certainty and Competitiveness for American Job Creators, Subchapter A--Permanent U.S. Business Tax Reforms and Boosting Domestic Investment, Sec. 70301: Full Expensing for Certain Business Property, Sec. 70303: Modification of Limitation on Business Interest, and Sec. 70306: Increased Dollar Limitation for Expensing of Certain Depreciable Assets; Chapter 4--Investing in American Families, Communities, and Small Businesses, Subchapter C--Permanent Investments in Community Development, Sec. 70421: Permanent Renewal and Enhancement of Opportunity Zones and Sec. 70422: Permanent Enhancement of Low-Income Housing Tax Credit; Chapter 5--Ending Green New Deal Spending, Promoting America-First Energy and Other Reforms, Subchapter A--Termination of Green New Deal Subsidies, Sec. 70507: Termination of Energy Efficient Commercial Buildings Deduction, Sec. 70508: Termination of New Energy Efficient Home Credit, Sec. 70513: Phase-Out and Restrictions on Clean Electricity Production Credit, and Sec. 70512: Phase-Out and Restrictions on Clean Electricity Investment Credit; and Chapter 6--Enhancing Deduction and Income Tax Guardrails, and Other Reforms, Subchapter A--Enhancing Deduction Guardrails and Other Reforms, Sec 70601: Limitation on Individual Deductions for Certain State and Local Taxes, etc. (SALT) and Addressing SALT Workarounds and Sec. 70602: Extension and Modification of Limitation on Excess Business Losses of Noncorporate Taxpayers H.R. 703, Main Street Tax Certainty Act, to amend the Internal Revenue Code of 1986 to make permanent the deduction for qualified business income, all provisions. S. 213, Main Street Tax Certainty Act, to amend the Internal Revenue Code of 1986 to make permanent the deduction for qualified business income, all provisions. H.Con.Res. 14, Establishing the congressional budget for the United States Government for fiscal year 2025 and setting forth the appropriate budgetary levels for fiscal years 2026 through 2034, provisions impacting tax policy Revenue-Raising Provisions NMHC opposes imposing the net investment income tax (NIIT) on active income while also potentially increasing the NIIT rate. NMHC opposes requiring 100-percent recapture of depreciation deductions as ordinary income for real estate. NMHC opposes restricting the deductibility of state and local taxes (e.g., income, property, and industry-related taxes) by pass-through entities and REITs. NMHC supports retaining current law with regard to like-kind exchanges. NMHC believes that carried interest should be treated as a long-term capital gain if the underlying asset is held for at least one year. Low-Income Housing Tax Credit and Middle-Income Housing Tax Credit Workforce Housing Tax Credit: NMHC supports the establishment of a Workforce Housing Tax Credit to spur production of multifamily housing for households earning up to 100 percent of area median income. Low-Income Housing Tax Credit: We support increasing credit authority and reducing the bond financing test. We also support increasing the private-activity bond volume cap to increase the use of 4 percent Low-Income Housing Tax Credits S. 3436 (118th Congress), Workforce Housing Tax Credit Act, to amend the Internal Revenue Code of 1986 to provide a credit for middle-income housing, and for other purposes, all provisions. H.R. 6686 (118th Congress), Workforce Housing Tax Credit Act, to amend the Internal Revenue Code of 1986 to provide a credit for middle-income housing, and for other purposes, all provisions. H.R. 2725, Affordable Housing Credit Improvement Act of 2025, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions, in particular issues relating to increased tax credit authority and tax-exempt bond financing requirements. S. 1515, Affordable Housing Credit Improvement Act of 2025, a bill to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. Adaptive Reuse H.R. 2410, Revitalizing Downtowns and Main Streets Act, to amend the Internal Revenue Code of 1986 to provide an investment credit for converting non-residential buildings to affordable housing, all provisions. Opportunity Zones NMHC supports: (1) Enabling States to recertify and/or redesignate Opportunity Zones to account for current economic realities and changes since Zones were originally designated; (2) Establishing new deferral deadlines so that taxpayers are incentivized to receive both a longer deferral period and the potential for a 10 percent or 15 percent basis increase with respect to reinvested capital gains; and (3) Reducing the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes. H.R. 5761 (118th Congress), Opportunity Zones Transparency, Extension, and Improvement Act, to amend the Internal Revenue Code of 1986 to modify the rules relating to qualified opportunity zones, and for other purposes, all provisions Tax Depreciation NMHC believes Congress should consider proposals to shorten the depreciation recovery period of multifamily structures while opposing measures to increase the 25 percent depreciation recapture rate applicable to sales. Also studied proposals to shorten depreciation recovery period of affordable multifamily housing units. Litigation and Tax Impact S. 1821, Tackling Predatory Litigation Funding Act, to amend the Internal Revenue Code of 1986 to establish a tax on income from litigation which is received by third-party entities that provided financing for such litigation, all provisions. H.R. 3512, Tackling Predatory Litigation Funding Act, to amend the Internal Revenue Code of 1986 to establish a tax on income from litigation which is received by third-party entities that provided financing for such litigation, all provisions. Tax Regulations Department of the Treasury and Internal Revenue Service, 26 CFR Part 1, TD 9992, RIN 1545-BQ36, Guidance on the Definition of Domestically Controlled Investment Entities. Department of the Treasury, Internal Revenue Service, 26 CFR Part 1, TD 10028, RIN 1545-BR07, Certain Partnership Related-Party Basis Adjustment Transactions as Transactions of Interest. Internal Revenue Service, Notice 2025-23, Notice of Intent to Remove 26 CFR 1.6011-18; Waiver of Penalties under Sections 6707A(a), 6707(a), and 6708; Withdrawal of Notice 2024-54.

H.R. 1 One Big Beautiful Bill Act" Energy efficiency and clean energy tax incentives, including the E-QUIP Act and Inflation Reduction Act, and regulatory implementation Like-Kind Exchanges (Sec. 1031) Completed contract method of accounting and condominium construction (Section 460(e) Fair Accounting for Condominium Construction Act (HR 4280) FIRPTA reform and Parity for Non-Traded REITS Act Net investment income tax and SECA liability Cost recovery, residential rental property and nonresidential property Low-income housing tax credit and the Affordable Housing Credit Improvement Act (S 1557 and HR 3238) Proposed and final tax regulations under section 897 and 892 (FIRPTA domestically controlled REIT rules) REIT rules, including investments in related parties Retail Revitalization Act of 2023 (HR 3749) Cancellation of Indebtedness income (section 108) (HR 5580, Saving Our Mainstreet American Locations for Leisure and Shopping Act) Capital gains tax rate State and local tax deduction 20% deduction for pass-through business income (section 199A) and tax rules on pass-through income, including Senator Wyden pass-through reform discussion draft Taxing appreciated capital gains at death Opportunity Zone reform, reporting, and deadline extensions (HR 5761, Opportunity Zones Transparency, Extension and Improvement Act) Revitalizing Downtowns Act and tax incentives for property conversions (HR 9002) Taxing unrealized gains annually - Administration's minimum tax proposal and Chairman Wyden proposal TCJA Permanency Act and issues related to extension of TCJA Business interest deductibility and section 163(j) Active loss limitation and section 461(l) S. 2518, Ending Tax Breaks for Massive Sovereign Wealth Funds Act S. 2224, Stop Predatory Investing Act Treasury guidance: partnership basis-shifting transactions SECA limited partner exception under section 1402(a)(13) Tax and revenue provisions in the budget resolution Deductibility of state and local business taxes, including property taxes (Business SALT)

"Carried Interest Fairness Act" and carried interest reform, including changes in holding period Energy efficiency and clean energy tax incentives, including the E-QUIP Act and Inflation Reduction Act, and regulatory implementation Like-Kind Exchanges (Sec. 1031) Completed contract method of accounting and condominium construction (Section 460(e) Fair Accounting for Condominium Construction Act (HR 4280) FIRPTA reform and Parity for Non-Traded REITS Act Net investment income tax and SECA liability Cost recovery, residential rental property and nonresidential property Low-income housing tax credit and the Affordable Housing Credit Improvement Act (S 1557 and HR 3238) Proposed and final tax regulations under section 897 and 892 (FIRPTA domestically controlled REIT rules) REIT rules, including investments in related parties Retail Revitalization Act of 2023 (HR 3749) Cancellation of Indebtedness income (section 108) (HR 5580, Saving Our Mainstreet American Locations for Leisure and Shopping Act) Capital gains tax rate State and local tax deduction 20% deduction for pass-through business income (section 199A) and tax rules on pass-through income, including Senator Wyden pass-through reform discussion draft Taxing appreciated capital gains at death Opportunity Zone reform, reporting, and deadline extensions (HR 5761, Opportunity Zones Transparency, Extension and Improvement Act) Revitalizing Downtowns Act and tax incentives for property conversions (HR 9002) Taxing unrealized gains annually - Administration's minimum tax proposal and Chairman Wyden proposal TCJA Permanency Act and issues related to extension of TCJA Business interest deductibility and section 163(j) Active loss limitation and section 461(l) S. 2518, Ending Tax Breaks for Massive Sovereign Wealth Funds Act S. 2224, Stop Predatory Investing Act Treasury guidance: partnership basis-shifting transactions SECA limited partner exception under section 1402(a)(13) Tax and revenue provisions in the budget resolution Deductibility of state and local business taxes, including property taxes (Business SALT)

"Carried Interest Fairness Act" and carried interest reform, including changes in holding period Energy efficiency and clean energy tax incentives, including the E-QUIP Act and Inflation Reduction Act, and regulatory implementation Like-Kind Exchanges (Sec. 1031) Completed contract method of accounting and condominium construction (Section 460(e) Fair Accounting for Condominium Construction Act (HR 4280) FIRPTA reform and Parity for Non-Traded REITS Act Net investment income tax and SECA liability Cost recovery, residential rental property and nonresidential property Low-income housing tax credit and the Affordable Housing Credit Improvement Act (S 1557 and HR 3238) Proposed and final tax regulations under section 897 and 892 (FIRPTA domestically controlled REIT rules) REIT rules, including investments in related parties Retail Revitalization Act of 2023 (HR 3749) Cancellation of Indebtedness income (section 108) (HR 5580, Saving Our Mainstreet American Locations for Leisure and Shopping Act) Capital gains tax rate State and local tax deduction 20% deduction for pass-through business income (section 199A) and tax rules on pass-through income, including Senator Wyden pass-through reform discussion draft Taxing appreciated capital gains at death Opportunity Zone reform, reporting, and deadline extensions (HR 5761, Opportunity Zones Transparency, Extension and Improvement Act) Revitalizing Downtowns Act and tax incentives for property conversions (HR 9002) Taxing unrealized gains annually - Administration's minimum tax proposal and Chairman Wyden proposal TCJA Permanency Act and issues related to extension of TCJA Business interest deductibility and section 163(j) Active loss limitation and section 461(l) S. 2518, Ending Tax Breaks for Massive Sovereign Wealth Funds Act S. 2224, Stop Predatory Investing Act Treasury guidance: partnership basis-shifting transactions SECA limited partner exception under section 1402(a)(13) Tax and revenue provisions in the budget resolution Deductibility of state and local business taxes, including property taxes (Business SALT)

Tax Cuts and Job Act Permanency NMHC supports making permanent individual tax rates and the 20 percent qualified business income tax deduction that expire at the end of 2025. NMHC supports making permanent the Estate Tax rules enacted as part of the Tax Cuts and Jobs Act of 2017 (TCJA). In TCJA, Congress, doubled the estate tax exclusion through 2025 while retaining a top tax rate of 40 percent and stepped-up basis rules. H.R. 703, Main Street Tax Certainty Act, to amend the Internal Revenue Code of 1986 to make permanent the deduction for qualified business income, all provisions. S. 213, Main Street Tax Certainty Act, to amend the Internal Revenue Code of 1986 to make permanent the deduction for qualified business income, all provisions. H.R. 4721 (118th Congress), Main Street Tax Certainty Act, to amend the Internal Revenue Code of 1986 to make permanent the deduction for qualified business income, all provisions. S. 1706 (118th Congress), Main Street Tax Certainty Act, to amend the Internal Revenue Code of 1986 to make permanent the deduction for qualified business income, all provisions. H.R. 1301, Death Tax Repeal Act, to amend the Internal Revenue Code of 1986 to repeal the estate and generation-skipping transfer taxes, all provisions. S. 587, Death Tax Repeal Act of 2025, a bill to amend the Internal Revenue Code of 1986 to repeal the estate and generation-skipping transfer taxes, and for other purposes, all provisions. H.Con.Res. 14, Establishing the congressional budget for the United States Government for fiscal year 2025 and setting forth the appropriate budgetary levels for fiscal years 2026 through 2034, provisions impacting tax policy Revenue-Raising Provisions NMHC opposes imposing the net investment income tax (NIIT) on active income while also potentially increasing the NIIT rate. NMHC opposes requiring 100-percent recapture of depreciation deductions as ordinary income for real estate. NMHC opposes restricting the deductibility of state and local taxes (e.g., income, property, and industry-related taxes) by pass-through entities and REITs. NMHC supports retaining current law with regard to like-kind exchanges. NMHC believes that carried interest should be treated as a long-term capital gain if the underlying asset is held for at least one year.  H.R. 1091, Carried Interest Fairness Act of 2025, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-thru entities, all provisions S. 445, Carried Interest Fairness Act of 2025, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-thru entities, all provisions Low-Income Housing Tax Credit and Middle-Income Housing Tax Credit Workforce Housing Tax Credit: NMHC supports the establishment of a Workforce Housing Tax Credit to spur production of multifamily housing for households earning up to 100 percent of area median income. Low-Income Housing Tax Credit: We support increasing credit authority and reducing the bond financing test. We also support increasing the private-activity bond volume cap to increase the use of 4 percent Low-Income Housing Tax Credits S. 3436 (118th Congress), Workforce Housing Tax Credit Act, to amend the Internal Revenue Code of 1986 to provide a credit for middle-income housing, and for other purposes, all provisions. H.R. 6686 (118th Congress), Workforce Housing Tax Credit Act, to amend the Internal Revenue Code of 1986 to provide a credit for middle-income housing, and for other purposes, all provisions. H.R. 3238 (118th Congress), Affordable Housing Credit Improvement Act of 2023, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions, in particular provisions relating to increased tax credit authority and tax-exempt bond financing requirements. S. 1557 (118th Congress), Affordable Housing Credit Improvement Act of 2023, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions, in particular provisions relating to increased tax credit authority and tax-exempt bond financing requirements. Adaptive Reuse H.R. 2410, Revitalizing Downtowns and Main Streets Act, to amend the Internal Revenue Code of 1986 to provide an investment credit for converting non-residential buildings to affordable housing, all provisions. H.R. 9002 (118th Congress), Revitalizing Downtowns and Main Streets Act, to amend the Internal Revenue Code of 1986 to provide an investment credit for converting non-residential buildings to affordable housing, all provisions. S. 4693 (118th Congress), Revitalizing Downtowns and Main Streets Act, to amend the Internal Revenue Code of 1986 to provide an investment credit for converting non-residential buildings to affordable housing, all provisions. Opportunity Zones NMHC supports: Enabling States to recertify and/or redesignate Opportunity Zones to account for current economic realities and changes since Zones were originally designated; (2) Establishing new deferral deadlines so that taxpayers are incentivized to receive both a longer deferral period and the potential for a 10 percent or 15 percent basis increase with respect to reinvested capital gains; and (3) Reducing the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes. H.R. 5761 (118th Congress), Opportunity Zones Transparency, Extension, and Improvement Act, to amend the Internal Revenue Code of 1986 to modify the rules relating to qualified opportunity zones, and for other purposes, all provisions Housing Preservation Draft legislative proposal, Housing Opportunities and Preservation Enhancement Act of 2025, to preserve aging affordable rental housing properties by creating tax incentives for individual investors that fund rehabilitation and preservation of existing affordable rental housing, all provisions. Brownfields H.R. 815, Brownfields Redevelopment Tax Incentive Reauthorization Act of 2025, to amend the Internal Revenue Code of 1986 to extend expensing of environmental remediation costs, all provisions. Role of Partnerships Promotion of partnerships as business entity. Tax Regulations Department of the Treasury and Internal Revenue Service, 26 CFR Part 1, TD 9992, RIN 1545-BQ36, Guidance on the Definition of Domestically Controlled Investment Entities. Department of the Treasury, Internal Revenue Service, 26 CFR Part 1, TD 10028, RIN 1545-BR07, Certain Partnership Related-Party Basis Adjustment Transactions as Transactions of Interest. Potential Congressional Review Act legislation to nullify Department of the Treasury, Internal Revenue Service, 26 CFR Part 1, TD 10028, RIN 1545-BR07, Certain Partnership Related-Party Basis Adjustment Transactions as Transactions of Interest. Income and rent limits under Internal Revenue Code Sections 42 and 142: Considered signing letter to request that Treasury and Internal Revenue Service issue guidance clarifying that: (1) the Housing and Economic Recovery Act of 2008 (HERA) income rules related to hold harmless start no later than allocation or low-income housing tax credit determination; (2) hold harmless and HERA Special incomes do not reset upon resyndication; and (3) hold harmless treatment would apply at the national non-metro amount for rural projects.

Issues related to H.R.6833, Improve and Enhance the Work Opportunity Tax Credit Act, H.R.5761, Opportunity Zones Transparency, Extension, and Improvement Act, H.R.4721/S.1706, Main Street Tax Certainty Act, and H.R.3624/S.3345, Travel Trailer and Camper Tax Parity Act.

Client expense: Not reported · Firm income: $120,000

Issues relating to economic development of distressed communities, including IRC section 1400Z, S.4065, and H.R.5761 (Opportunity Zones).

Client expense: $190,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues relating to economic development of distressed communities, including IRC section 1400Z, S.4065, and H.R.5761 (Opportunity Zones). Issues relating to non-compete agreements and their effects on economic dynamism, including S.220 and H.R.731 (Workforce Mobility Act of 2023). Issues relating to demographic trends, labor force issues and the availability of human capital, including immigration and S.5644 (Heartland Visa Act of 2024). Issues relating to inclusive wealth building and retirement security, including H.R.6065, and S.3102 (Retirement Savings for Americans Act). Issues related to increasing technology and innovation, including H.R.4346. Issues relating to housing and housing supply.

Client expense: $190,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Discussions involving H.R. 8647, the VA Home Loan Program Reform Act Discussions involving the Federal Housing Finance Agency and Freddie Mac second lien proposal Discussions involving S. 3728, the Veterans Housing Stability Act of 2024 Discussions involving housing finance reform legislation Monitored S. 1688 / H.R. 3507, the Yes In My Backyard (YIMBY) Act Monitored H.R. 5761, the Opportunity Zones Transparency, Extension, and Improvement Act Monitored S. 1514 / H.R. 3170, the Homes for Every Local Protector, Educator, and Responder (HELPER) Act of 2023 Monitored the implementation of P.L. 116-136, the CARES Act (provisions related to mortgage forbearance for consumers and liquidity for mortgage servicers) Monitored H.R. 3564, the Middle Class Borrower Protection Act of 2023 Monitored H.R. 1059, the SECURE Notarization Act of 2023 Monitored H.R. 4335, the VA Loan Informed Disclosure Act of 2023 Monitored S. 2496, the VALID Act of 2023 Monitored S. 3068 / H.R. 5979, the VA Home Loan Awareness Act of 2023 Monitored executive branch nominations to federal agencies and commissions

Client expense: Not reported · Firm income: $60,000

"Carried Interest Fairness Act" and carried interest reform, including changes in holding period Energy efficiency and clean energy tax incentives, including the E-QUIP Act and Inflation Reduction Act, and regulatory implementation Like-Kind Exchanges (Sec. 1031) Completed contract method of accounting and condominium construction (Section 460(e) Fair Accounting for Condominium Construction Act (HR 4280) FIRPTA reform and Parity for Non-Traded REITS Act Net investment income tax and SECA liability Cost recovery, residential rental property and nonresidential property Low-income housing tax credit and the Affordable Housing Credit Improvement Act (S 1557 and HR 3238) Proposed and final tax regulations under section 897 and 892 REIT rules, including investments in related parties Retail Revitalization Act of 2023 (HR 3749) Cancellation of Indebtedness income (section 108) (HR 5580, Saving Our Mainstreet American Locations for Leisure and Shopping Act) Capital gains tax rate State and local tax deduction 20% deduction for pass-through business income (section 199A) and tax rules on pass-through income, including Senator Wyden pass-through reform discussion draft Taxing appreciated capital gains at death Opportunity Zone reform, reporting, and deadline extensions (HR 5761, Opportunity Zones Transparency, Extension and Improvement Act) Estate tax valuation discounts and rules for grantor trusts Revitalizing Downtowns Act and tax incentives for property conversions Passive Foreign Investment Company proposed tax regulations (REG-118250-20) Taxing unrealized gains annually - Administration's minimum tax proposal and Chairman Wyden proposal TCJA Permanency Act Business interest deductibility and section 163(j) Active loss limitation and section 461(l) S. 2518, Ending Tax Breaks for Massive Sovereign Wealth Funds Act S. 2224, Stop Predatory Investing Act Tax Relief for American Families and Workers Act (H.R. 7024)

TCJA Permanency, Tax Issues in Biden Administrations Fiscal Year 2025 Budget, and Other Proposals Impacting Pass-Through Entities NMHC supports making permanent individual tax rates and the 20 percent qualified business income tax deduction that expires at the end of 2025. S. 1706, Main Street Tax Certainty Act, to amend the Internal Revenue Code of 1986 to make permanent the deduction for qualified business income, all provisions. H.R. 4721, Main Street Tax Certainty Act, to amend the Internal Revenue Code of 1986 to make permanent the deduction for qualified business income, all provisions. H.R. 7024, Tax Relief for American Families and Workers Act of 2024, Title II -- American Innovation and Growth, Section 202: Extension of allowance for depreciation, amortization, or depletion in determining the limitation on business interest, Section 203: Extension of 100 percent bonus depreciation, and Section 204: Increase in limitations on expensing of depreciable business assets; Title V -- More Affordable Housing, Section 501: State housing credit allowance ceiling increase for low-income housing credit and Section 502: Tax-exempt bond financing requirement. General Explanations of the Administration's Fiscal Year 2025 Revenue Proposals: Provide a neighborhood homes credit; Expand and enhance the Low-Income Housing Tax Credit; Apply the net investment income tax to pass-through business income of high-income taxpayers; Increase the net investment income tax rate and additional Medicare tax rate for high-income taxpayers; Increase the top marginal income tax rate for high-income earners; Reform the taxation of capital income (tax capital income for high-income earners at ordinary rates and treat transfers of appreciated property by gift or on death as realization events); Tax carried (profits) interests as ordinary income; Repeal deferral of gain from like-kind exchanges; and Require 100 percent depreciation recapture of depreciation deductions as ordinary income for certain depreciable real property. Senator Wyden Pass-Through Reform Discussion Draft (2021), all provisions. Promotion of partnerships as business entity Estate Tax, Stepped-Up Basis, and Taxation of Unrealized Capital Gains at Death NMHC supports making permanent the Estate Tax rules enacted as part of the Tax Cuts and Jobs Act of 2017 (TCJA). In TCJA, Congress, doubled the estate tax exclusion through 2025 while retaining a top tax rate of 40 percent and stepped-up basis rules. NMHC supports retaining current law providing for stepped-up basis at death and taxation of capital gains upon actual sale. NMHC opposes taxing unrealized gains at death. Carried Interest NMHC believes that carried interest should be treated as a long-term capital gain if the underlying asset is held for at least one year.  Like-Kind Exchanges NMHC supports retaining current law. Depreciation Biden Administration legislative proposal to cap rent increases at 5 percent by denying faster depreciation write offs to available to owners of rental housing. Congress should oppose measures to increase the 25 percent depreciation recapture rate applicable to sales. Low-Income Housing Tax Credit and Middle-Income Housing Tax Credit S. 3436, Workforce Housing Tax Credit Act, to amend the Internal Revenue Code of 1986 to provide a credit for middle-income housing, and for other purposes, all provisions. H.R. 6686, Workforce Housing Tax Credit Act, to amend the Internal Revenue Code of 1986 to provide a credit for middle-income housing, and for other purposes, all provisions. H.R. 3238, Affordable Housing Credit Improvement Act of 2023, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions, in particular issues relating to increased tax credit authority and tax-exempt bond financing requirements. S. 1557, Affordable Housing Credit Improvement Act of 2023, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions, in particular issues relating to increased tax credit authority and tax-exempt bond financing requirements. H.R. 10195, No Discrimination in Housing Act, to amend the Internal Revenue Code of 1986 to disallow the low-income housing tax credit to taxpayers that have diversity, equity, and inclusion initiatives, all provisions. NMHC supports an increase in the private-activity bond volume cap to enhance the use of 4 percent Low-Income Housing Tax Credits. Analyzed proposals to potentially modify Affordable Housing Credit Improvement Act in 119th Congress, including those pertaining to: Increasing state allocations; modifying student occupancy rules; clarifying Violence Against Women Act provisions; eliminating the 10-year rule and reducing the related party prohibition period to two years; revising and clarifying the treatment of refunding issues; increasing LIHTC program transparency; easing the Section 38(c)(1)(B) cap on the ability to use LIHTCs; extending the carryback period for Housing Credits; exempting multifamily bond authority used for recapitalization and rehabilitation of Housing Credit developments from state private activity bond cap; repealing the qualified contract rule prospectively; providing a purchase option as an alternative to the right of first refusal for limited partnership agreements entered into by nonprofits after the date of enactment; allowing states to extend the placed in service deadline by up to 12 months; requiring owners to provide notice of expiring affordability to local governments and tenants; excluding the value of certain energy benefits, such as grants and rebates, from gross income for tax purposes; and facilitating GSE investment in rural Housing Credit properties. Adaptive Reuse H.R. 9002, Revitalizing Downtowns and Main Streets Act, to amend the Internal Revenue Code of 1986 to provide an investment credit for converting non-residential buildings to affordable housing, all provisions. S. 4693, Revitalizing Downtowns and Main Streets Act, to amend the Internal Revenue Code of 1986 to provide an investment credit for converting non-residential buildings to affordable housing, all provisions. H.R.419 - Revitalizing Downtowns Act, to amend the Internal Revenue Code of 1986 to provide an investment credit for the conversion of office buildings into other uses, all provisions. S. 2511 (117th Congress), Revitalizing Downtowns Act, to amend the Internal Revenue Code of 1986 to provide an investment credit for the conversion of office buildings into other uses, all provisions. Opportunity Zones NMHC supports: (1) Enabling States to recertify and/or redesignate Opportunity Zones to account for current economic realities and changes since Zones were originally designated; (2) Establishing new deferral deadlines so that taxpayers are incentivized to receive both a longer deferral period and the potential for a 10 percent or 15 percent basis increase with respected to reinvested capital gains; and (3) Reducing the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes. H.R. 5761, Opportunity Zones Transparency, Extension, and Improvement Act, to amend the Internal Revenue Code of 1986 to modify the rules relating to qualified opportunity zones, and for other purposes, all provisions.

Issues related to IRC section 1400Z. (H.R. 5761)

Client expense: Not reported · Firm income: $50,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

"Carried Interest Fairness Act" and carried interest reform, including changes in holding period Energy efficiency and clean energy tax incentives, including the E-QUIP Act and Inflation Reduction Act, and regulatory implementation Like-Kind Exchanges (Sec. 1031) Completed contract method of accounting and condominium construction (Section 460(e) Fair Accounting for Condominium Construction Act (HR 4280) FIRPTA reform and Parity for Non-Traded REITS Act Net investment income tax and SECA liability Cost recovery, residential rental property and nonresidential property Low-income housing tax credit and the Affordable Housing Credit Improvement Act (S 1557 and HR 3238) Proposed and final tax regulations under section 897 and 892 REIT rules, including investments in related parties Retail Revitalization Act of 2023 (HR 3749) Cancellation of Indebtedness income (section 108) (HR 5580, Saving Our Mainstreet American Locations for Leisure and Shopping Act) Capital gains tax rate State and local tax deduction 20% deduction for pass-through business income (section 199A) and tax rules on pass-through income, including Senator Wyden pass-through reform discussion draft Taxing appreciated capital gains at death Opportunity Zone reform, reporting, and deadline extensions (HR 5761, Opportunity Zones Transparency, Extension and Improvement Act) Revitalizing Downtowns Act and tax incentives for property conversions (HR 9002) Passive Foreign Investment Company proposed tax regulations (REG-118250-20) Taxing unrealized gains annually - Administration's minimum tax proposal and Chairman Wyden proposal TCJA Permanency Act and issues related to extension of TCJA Business interest deductibility and section 163(j) Active loss limitation and section 461(l) S. 2518, Ending Tax Breaks for Massive Sovereign Wealth Funds Act S. 2224, Stop Predatory Investing Act Tax Relief for American Families and Workers Act (H.R. 7024) Treasury guidance: partnership basis-shifting transactions SECA limited partner exception under section 1402(a)(13)

HR 5580, Saving Our Mainstreet American Locations for Leisure and Shopping Act - ALL S 1706/HR 4721, Main Street Tax Certainty Act - ALL HR 9002/S 4693 Revitalizing Downtowns and Main Streets Act - ALL HR 7024 Tax Relief for American Families and Workers Act - Sec. 202-204 IRC Section 1031 - maintaining current treatment - no bill IRC Sec 1061 - maintaining current treatment - no bill IRC Section 118 - to provide that certain contributions by government entities are treated as contributions to capital - no bill Wyden Pass-Through Reform - no bill, discussion draft - ALL H.R. 419, Revitalizing Downtowns Act - enhancements to facilitate conversion of commercial buildings into other uses - ALL H.R. 2686, Ending Wall Street Tax Giveaway Act - ALL S. 3317 Ending the Carried Interest Loophole Act - ALL H.R. 3749, Retail Revitalization Act of 2023 - ALL H.R. 5761 Opportunity Zones Transparency, Extension & Improvement Act, ALL S. 4123 Carried Interest Fairness Act - ALL

Client expense: $350,000 · Firm income: Not reported

"Carried Interest Fairness Act" and carried interest reform, including changes in holding period Energy efficiency and clean energy tax incentives, including the E-QUIP Act and Inflation Reduction Act, and regulatory implementation Like-Kind Exchanges (Sec. 1031) Completed contract method of accounting and condominium construction (Section 460(e) Fair Accounting for Condominium Construction Act (HR 4280) FIRPTA reform and Parity for Non-Traded REITS Act Net investment income tax and SECA liability Cost recovery, residential rental property and nonresidential property Low-income housing tax credit and the Affordable Housing Credit Improvement Act (S 1557 and HR 3238) Proposed and final tax regulations under section 897 and 892 REIT rules, including investments in related parties Retail Revitalization Act of 2023 (HR 3749) Cancellation of Indebtedness income (section 108) (HR 5580, Saving Our Mainstreet American Locations for Leisure and Shopping Act) Capital gains tax rate State and local tax deduction 20% deduction for pass-through business income (section 199A) and tax rules on pass-through income, including Senator Wyden pass-through reform discussion draft Taxing appreciated capital gains at death Opportunity Zone reform, reporting, and deadline extensions (HR 5761, Opportunity Zones Transparency, Extension and Improvement Act) Estate tax valuation discounts and rules for grantor trusts Revitalizing Downtowns Act and tax incentives for property conversions Passive Foreign Investment Company proposed tax regulations (REG-118250-20) Taxing unrealized gains annually - Administration's minimum tax proposal and Chairman Wyden proposal TCJA Permanency Act Business interest deductibility and section 163(j) Active loss limitation and section 461(l) S. 2518, Ending Tax Breaks for Massive Sovereign Wealth Funds Act S. 2224, Stop Predatory Investing Act Tax Relief for American Families and Workers Act (H.R. 7024)

Issues related to H.R.6833, Improve and Enhance the Work Opportunity Tax Credit Act, H.R.5761, Opportunity Zones Transparency, Extension, and Improvement Act, H.R.4721/S.1706, Main Street Tax Certainty Act, and H.R.3624/S.3345, Travel Trailer and Camper Tax Parity Act.

Client expense: Not reported · Firm income: $120,000

TCJA Permanency, Tax Issues in Biden Administrations Fiscal Year 2025 Budget, and Other Proposals Impacting Pass-Through Entities NMHC supports making permanent individual tax rates and the 20 percent qualified business income tax deduction that expire at the end of 2025. S. 1706, Main Street Tax Certainty Act, to amend the Internal Revenue Code of 1986 to make permanent the deduction for qualified business income, all provisions. H.R. 4721, Main Street Tax Certainty Act, to amend the Internal Revenue Code of 1986 to make permanent the deduction for qualified business income, all provisions. H.R. 7024, Tax Relief for American Families and Workers Act of 2024, Title II -- American Innovation and Growth, Section 202: Extension of allowance for depreciation, amortization, or depletion in determining the limitation on business interest, Section 203: Extension of 100 percent bonus depreciation, and Section 204: Increase in limitations on expensing of depreciable business assets; Title V -- More Affordable Housing, Section 501: State housing credit allowance ceiling increase for low-income housing credit and Section 502: Tax-exempt bond financing requirement. General Explanations of the Administration's Fiscal Year 2025 Revenue Proposals: Expand and enhance the Low-Income Housing Tax Credit; Apply the net investment income tax to pass-through business income of high-income taxpayers; Increase the net investment income tax rate and additional Medicare tax rate for high-income taxpayers; Increase the top marginal income tax rate for high-income earners; Reform the taxation of capital income (tax capital income for high-income earners at ordinary rates and treat transfers of appreciated property by gift or on death as realization events); Tax carried (profits) interests as ordinary income; Repeal deferral of gain from like-kind exchanges; and Require 100 percent depreciation recapture of depreciation deductions as ordinary income for certain depreciable real property. Senator Wyden Pass-Through Reform Discussion Draft (2021), all provisions. Promotion of partnerships as business entity Estate Tax, Stepped-Up Basis, and Taxation of Unrealized Capital Gains at Death NMHC supports making permanent the Estate Tax rules enacted as part of the Tax Cuts and Jobs Act of 2017 (TCJA). In TCJA, Congress, doubled the estate tax exclusion through 2025 while retaining a top tax rate of 40 percent and stepped-up basis rules. NMHC supports retaining current law providing for stepped-up basis at death and taxation of capital gains upon actual sale. NMHC opposes taxing unrealized gains at death. Carried Interest NMHC believes that carried interest should be treated as a long-term capital gain if the underlying asset is held for at least one year.  Like-Kind Exchanges NMHC supports retaining current law. Depreciation Biden Administration legislative proposal to cap rent increases at 5 percent by denying faster depreciation write offs to available to owners of rental housing. Congress should oppose measures to increase the 25 percent depreciation recapture rate applicable to sales. Low-Income Housing Tax Credit and Middle-Income Housing Tax Credit S. 3436, Workforce Housing Tax Credit Act, to amend the Internal Revenue Code of 1986 to provide a credit for middle-income housing, and for other purposes, all provisions. H.R. 6686, Workforce Housing Tax Credit Act, to amend the Internal Revenue Code of 1986 to provide a credit for middle-income housing, and for other purposes, all provisions. H.R. 3238, Affordable Housing Credit Improvement Act of 2023, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions, in particular issues relating to increased tax credit authority and tax-exempt bond financing requirements. S. 1557, Affordable Housing Credit Improvement Act of 2023, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions, in particular issues relating to increased tax credit authority and tax-exempt bond financing requirements. NMHC supports an increase in the private-activity bond volume cap to enhance the use of 4 percent Low-Income Housing Tax Credits. Law that Low Income Housing Tax Credits are not available for the acquisition of properties placed in service during the last ten years ("Ten-Year Rule"): Considered proposals to: (1) Repeal the "Ten-Year Rule"; (2) Explicitly Define Substantially assisted, financed and Federally Assisted Building for the Purposes of the Ten-Year Rule ; and (3) Expand the Definition of Federally Assisted Building to include properties financed with LIHTCs in conjunction with financing from Fannie Mae or Freddie Mac. Adaptive Reuse H.R. 9002, Revitalizing Downtowns and Main Streets Act, to amend the Internal Revenue Code of 1986 to provide an investment credit for converting non-residential buildings to affordable housing, all provisions. S. 4693, Revitalizing Downtowns and Main Streets Act, to amend the Internal Revenue Code of 1986 to provide an investment credit for converting non-residential buildings to affordable housing, all provisions. Opportunity Zones NMHC supports: Enabling States to recertify and/or redesignate Opportunity Zones to account for current economic realities and changes since Zones were originally designated; (2) Establishing new deferral deadlines so that taxpayers are incentivized to receive both a longer deferral period and the potential for a 10 percent or 15 percent basis increase with respected to reinvested capital gains; and (3) Reducing the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes. H.R. 5761, Opportunity Zones Transparency, Extension, and Improvement Act, to amend the Internal Revenue Code of 1986 to modify the rules relating to qualified opportunity zones, and for other purposes, all provisions. H.R. 9203, Economic Opportunity for Distressed Communities Act, to amend the Internal Revenue Code of 1986 to establish special rules for capital gains invested in brownfield and superfund sites, all provisions.

HR 5580, Saving Our Mainstreet American Locations for Leisure and Shopping Act - ALL S 1706/HR 4721, Main Street Tax Certainty Act - ALL HR 9002/S 4693 Revitalizing Downtowns and Main Streets Act - ALL HR 7024 Tax Relief for American Families and Workers Act - Sec. 202-204 IRC Section 1031 - maintaining current treatment - no bill IRC Sec 1061 - maintaining current treatment - no bill IRC Section 118 - to provide that certain contributions by government entities are treated as contributions to capital - no bill Wyden Pass-Through Reform - no bill, discussion draft - ALL H.R. 419, Revitalizing Downtowns Act - enhancements to facilitate conversion of commercial buildings into other uses - ALL H.R. 2686, Ending Wall Street Tax Giveaway Act - ALL S. 3317 Ending the Carried Interest Loophole Act - ALL H.R. 3749, Retail Revitalization Act of 2023 - ALL H.R. 5761 Opportunity Zones Transparency, Extension & Improvement Act, ALL S. 4123 Carried Interest Fairness Act - ALL

Client expense: $330,000 · Firm income: Not reported

Issues relating to economic development of distressed communities, including IRC section 1400Z, S.4065, and H.R.5761 (Opportunity Zones).

Client expense: $100,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues relating to economic development of distressed communities, including IRC section 1400Z, S.4065, and H.R.5761 (Opportunity Zones). Issues relating to non-compete agreements and their effects on economic dynamism, including S.220 and H.R.731 (Workforce Mobility Act of 2023). Issues relating to demographic trends, labor force issues and the availability of human capital, including immigration. Issues relating to inclusive wealth building and retirement security, including H.R.6065, and S.3102 (Retirement Savings for Americans Act). Issues related to increasing technology and innovation, including H.R.4346.

Client expense: $100,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to IRC section 1400Z. (H.R. 5761)

Client expense: Not reported · Firm income: $50,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

"Carried Interest Fairness Act" and carried interest reform, including changes in holding period Energy efficiency and clean energy tax incentives, including the E-QUIP Act and Inflation Reduction Act, and regulatory implementation Like-Kind Exchanges (Sec. 1031) Completed contract method of accounting and condominium construction (Section 460(e) Fair Accounting for Condominium Construction Act (HR 4280) FIRPTA reform and Parity for Non-Traded REITS Act Net investment income tax and SECA liability Cost recovery, residential rental property and nonresidential property Low-income housing tax credit and the Affordable Housing Credit Improvement Act (S 1557 and HR 3238) Proposed and final tax regulations under section 897 and 892 REIT rules, including investments in related parties Retail Revitalization Act of 2023 (HR 3749) Cancellation of Indebtedness income (section 108) (HR 5580, Saving Our Mainstreet American Locations for Leisure and Shopping Act) Capital gains tax rate State and local tax deduction 20% deduction for pass-through business income (section 199A) and tax rules on pass-through income, including Senator Wyden pass-through reform discussion draft Taxing appreciated capital gains at death Opportunity Zone reform, reporting, and deadline extensions (HR 5761, Opportunity Zones Transparency, Extension and Improvement Act) Estate tax valuation discounts and rules for grantor trusts Revitalizing Downtowns Act and tax incentives for property conversions (HR 9002) Passive Foreign Investment Company proposed tax regulations (REG-118250-20) Taxing unrealized gains annually - Administration's minimum tax proposal and Chairman Wyden proposal TCJA Permanency Act and issues related to extension of TCJA Business interest deductibility and section 163(j) Active loss limitation and section 461(l) S. 2518, Ending Tax Breaks for Massive Sovereign Wealth Funds Act S. 2224, Stop Predatory Investing Act Tax Relief for American Families and Workers Act (H.R. 7024) Treasury guidance: partnership basis-shifting transactions SECA limited partner exception under section 1402(a)(13)

Issues relating to economic development of distressed communities, including IRC section 1400Z, S.4065, and H.R.5761 (Opportunity Zones). Issues relating to non-compete agreements and their effects on economic dynamism, including S.220 and H.R.731 (Workforce Mobility Act of 2023). Issues relating to demographic trends, labor force issues and the availability of human capital, including immigration. Issues relating to inclusive wealth building and retirement security, including H.R.6065, and S.3102 (Retirement Savings for Americans Act). Issues related to increasing technology and innovation, including H.R.4346.

Client expense: $120,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues relating to economic development of distressed communities, including IRC section 1400Z, S.4065, and H.R.5761 (Opportunity Zones).

Client expense: $120,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

"Carried Interest Fairness Act" and carried interest reform, including changes in holding period Energy efficiency and clean energy tax incentives, including the E-QUIP Act and Inflation Reduction Act, and regulatory implementation Like-Kind Exchanges (Sec. 1031) Completed contract method of accounting and condominium construction (Section 460(e) Fair Accounting for Condominium Construction Act (HR 4280) FIRPTA reform and Parity for Non-Traded REITS Act Net investment income tax and SECA liability Cost recovery, residential rental property and nonresidential property Low-income housing tax credit and the Affordable Housing Credit Improvement Act (S 1557 and HR 3238) Proposed and final tax regulations under section 897 and 892 REIT rules, including investments in related parties Retail Revitalization Act of 2023 (HR 3749) Cancellation of Indebtedness income (section 108) (HR 5580, Saving Our Mainstreet American Locations for Leisure and Shopping Act) Capital gains tax rate State and local tax deduction 20% deduction for pass-through business income (section 199A) and tax rules on pass-through income, including Senator Wyden pass-through reform discussion draft Taxing appreciated capital gains at death Opportunity Zone reform, reporting, and deadline extensions (HR 5761, Opportunity Zones Transparency, Extension and Improvement Act) Estate tax valuation discounts and rules for grantor trusts Revitalizing Downtowns Act and tax incentives for property conversions Passive Foreign Investment Company proposed tax regulations (REG-118250-20) Taxing unrealized gains annually - Administration's minimum tax proposal and Chairman Wyden proposal TCJA Permanency Act Business interest deductibility and section 163(j) Active loss limitation and section 461(l) S. 2518, Ending Tax Breaks for Massive Sovereign Wealth Funds Act S. 2224, Stop Predatory Investing Act Tax Relief for American Families and Workers Act (H.R. 7024) Treasury guidance: partnership basis-shifting transactions SECA limited partner exception under section 1402(a)(13)

"Carried Interest Fairness Act" and carried interest reform, including changes in holding period Energy efficiency and clean energy tax incentives, including the E-QUIP Act and Inflation Reduction Act, and regulatory implementation Like-Kind Exchanges (Sec. 1031) Completed contract method of accounting and condominium construction (Section 460(e) Fair Accounting for Condominium Construction Act (HR 4280) FIRPTA reform and Parity for Non-Traded REITS Act Net investment income tax and SECA liability Cost recovery, residential rental property and nonresidential property Low-income housing tax credit and the Affordable Housing Credit Improvement Act (S 1557 and HR 3238) Proposed and final tax regulations under section 897 and 892 REIT rules, including investments in related parties Retail Revitalization Act of 2023 (HR 3749) Cancellation of Indebtedness income (section 108) (HR 5580, Saving Our Mainstreet American Locations for Leisure and Shopping Act) Capital gains tax rate State and local tax deduction 20% deduction for pass-through business income (section 199A) and tax rules on pass-through income, including Senator Wyden pass-through reform discussion draft Taxing appreciated capital gains at death Opportunity Zone reform, reporting, and deadline extensions (HR 5761, Opportunity Zones Transparency, Extension and Improvement Act) Estate tax valuation discounts and rules for grantor trusts Revitalizing Downtowns Act and tax incentives for property conversions Passive Foreign Investment Company proposed tax regulations (REG-118250-20) Taxing unrealized gains annually - Administration's minimum tax proposal and Chairman Wyden proposal TCJA Permanency Act Business interest deductibility and section 163(j) Active loss limitation and section 461(l) S. 2518, Ending Tax Breaks for Massive Sovereign Wealth Funds Act S. 2224, Stop Predatory Investing Act Tax Relief for American Families and Workers Act (H.R. 7024)

HR 5580, Saving Our Mainstreet American Locations for Leisure and Shopping Act - ALL S 1706/HR 4721, Main Street Tax Certainty Act - ALL HR 976 TCJA Tax Permanency Act - Sec 111 Deduction for Qualified Business Income IRC Section 1031 - maintaining current treatment - no bill IRC Sec 1061 - maintaining current treatment - no bill IRC Section 118 - to provide that certain contributions by government entities are treated as contributions to capital - no bill Wyden Pass-Through Reform - no bill, discussion draft - ALL H.R. 419, Revitalizing Downtowns Act - enhancements to facilitate conversion of commercial buildings into other uses - ALL H.R. 2686, Ending Wall Street Tax Giveaway Act - ALL S. 3317 Ending the Carried Interest Loophole Act - ALL H.R. 3749, Retail Revitalization Act of 2023 - ALL H.R. 5761 Opportunity Zones Transparency, Extension & Improvement Act, ALL S. 4123 Carried Interest Fairness Act - ALL

Client expense: $330,000 · Firm income: Not reported

Issues related to IRC section 1400Z. (H.R. 5761)

Client expense: Not reported · Firm income: $50,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

"Carried Interest Fairness Act" and carried interest reform, including changes in holding period Energy efficiency and clean energy tax incentives, including the E-QUIP Act and Inflation Reduction Act, and regulatory implementation Like-Kind Exchanges (Sec. 1031) Completed contract method of accounting and condominium construction (Section 460(e) Fair Accounting for Condominium Construction Act (HR 4280) FIRPTA reform and Parity for Non-Traded REITS Act Net investment income tax and SECA liability Cost recovery, residential rental property and nonresidential property Low-income housing tax credit and the Affordable Housing Credit Improvement Act (S 1557 and HR 3238) Proposed and final tax regulations under section 897 and 892 REIT rules, including investments in related parties Retail Revitalization Act of 2023 (HR 3749) Cancellation of Indebtedness income (section 108) (HR 5580, Saving Our Mainstreet American Locations for Leisure and Shopping Act) Capital gains tax rate State and local tax deduction 20% deduction for pass-through business income (section 199A) and tax rules on pass-through income, including Senator Wyden pass-through reform discussion draft Taxing appreciated capital gains at death Opportunity Zone reform, reporting, and deadline extensions (HR 5761, Opportunity Zones Transparency, Extension and Improvement Act) Estate tax valuation discounts and rules for grantor trusts Revitalizing Downtowns Act and tax incentives for property conversions Passive Foreign Investment Company proposed tax regulations (REG-118250-20) Taxing unrealized gains annually - Administration's minimum tax proposal and Chairman Wyden proposal TCJA Permanency Act Business interest deductibility and section 163(j) Active loss limitation and section 461(l) S. 2518, Ending Tax Breaks for Massive Sovereign Wealth Funds Act S. 2224, Stop Predatory Investing Act Tax Relief for American Families and Workers Act (H.R. 7024)

Issues relating to economic development of distressed communities, including IRC section 1400Z, S.4065, and H.R.5761 (Opportunity Zones).

Client expense: $110,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues relating to economic development of distressed communities, including IRC section 1400Z, S.4065, and H.R.5761 (Opportunity Zones). Issues relating to non-compete agreements and their effects on economic dynamism, including S.220 and H.R.731 (Workforce Mobility Act of 2023). Issues relating to demographic trends, labor force issues and the availability of human capital, including immigration. Issues relating to inclusive wealth building and retirement security, including H.R.6065, and S.3102 (Retirement Savings for Americans Act). Issues related to increasing technology and innovation, including H.R.4346.

Client expense: $110,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

HR 5580, Saving Our Mainstreet American Locations for Leisure and Shopping Act - ALL S 1706/HR 4721, Main Street Tax Certainty Act - ALL HR 976 TCJA Tax Permanency Act - Sec 111 Deduction for Qualified Business Income IRC Section 1031 - maintaining current treatment - no bill IRC Sec 1061 - maintaining current treatment - no bill IRC Section 118 - to provide that certain contributions by government entities are treated as contributions to capital - no bill Wyden Pass-Through Reform - no bill, discussion draft - ALL H.R. 419, Revitalizing Downtowns Act - enhancements to facilitate conversion of commercial buildings into other uses - ALL H.R. 2686, Ending Wall Street Tax Giveaway Act - ALL S. 3317 Ending the Carried Interest Loophole Act - ALL H.R. 3749, Retail Revitalization Act of 2023 - ALL H.R. 5761 Opportunity Zones Transparency, Extension & Improvement Act, ALL

Client expense: $340,000 · Firm income: Not reported

"Carried Interest Fairness Act" and carried interest reform, including changes in holding period Energy efficiency and clean energy tax incentives, including the E-QUIP Act and Inflation Reduction Act, and regulatory implementation Like-Kind Exchanges (Sec. 1031) Completed contract method of accounting and condominium construction (Section 460(e) Fair Accounting for Condominium Construction Act (HR 4280) FIRPTA reform and Parity for Non-Traded REITS Act Net investment income tax and SECA liability Cost recovery, residential rental property and nonresidential property Low-income housing tax credit and the Affordable Housing Credit Improvement Act (S 1557 and HR 3238) Proposed and final tax regulations under section 897 and 892 REIT rules, including investments in related parties Retail Revitalization Act of 2023 (HR 3749) Cancellation of Indebtedness income (section 108) (HR 5580, Saving Our Mainstreet American Locations for Leisure and Shopping Act) Capital gains tax rate State and local tax deduction 20% deduction for pass-through business income (section 199A) and tax rules on pass-through income, including Senator Wyden pass-through reform discussion draft Taxing appreciated capital gains at death Opportunity Zone reform, reporting, and deadline extensions (HR 5761, Opportunity Zones Transparency, Extension and Improvement Act) Estate tax valuation discounts and rules for grantor trusts Revitalizing Downtowns Act and tax incentives for property conversions Passive Foreign Investment Company proposed tax regulations (REG-118250-20) Taxing unrealized gains annually - Administration's minimum tax proposal and Chairman Wyden proposal TCJA Permanency Act Business interest deductibility and section 163(j) Active loss limitation and section 461(l) S. 2518, Ending Tax Breaks for Massive Sovereign Wealth Funds Act S. 2224, Stop Predatory Investing Act Tax Relief for American Families and Workers Act (H.R. 7024)

Issues related to IRC section 1400Z. (H.R. 5761)

Client expense: Not reported · Firm income: $50,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues relating to economic development of distressed communities, including IRC section 1400Z, S.4065, and H.R.5761 (Opportunity Zones).

Client expense: $120,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues relating to economic development of distressed communities, including IRC section 1400Z, S.4065, and H.R.5761 (Opportunity Zones). Issues relating to non-compete agreements and their effects on economic dynamism, including S.220 and H.R.731 (Workforce Mobility Act of 2023). Issues relating to demographic trends, labor force issues and the availability of human capital, including immigration. Issues relating to inclusive wealth building and retirement security, including H.R.9462, S.5271, H.R.6065, and S.3102 (Retirement Savings for Americans Act). Issues related to increasing technology and innovation, including H.R.4346.

Client expense: $120,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues related to IRC section 1400Z. (H.R. 3937, H.R. 3906, H.R. 4055, H.R. 5761)

Client expense: Not reported · Firm income: $50,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

HR 5580, Saving Our Mainstreet American Locations for Leisure and Shopping Act - ALL S 1706/HR 4721, Main Street Tax Certainty Act - ALL HR 976 TCJA Tax Permanency Act - Sec 111 Deduction for Qualified Business Income IRC Section 1031 - maintaining current treatment - no bill IRC Sec 1061 - maintaining current treatment - no bill IRC Section 118 - to provide that certain contributions by government entities are treated as contributions to capital - no bill Wyden Pass-Through Reform - no bill, discussion draft - ALL H.R. 419, Revitalizing Downtowns Act - enhancements to facilitate conversion of commercial buildings into other uses - ALL H.R. 2686, Ending Wall Street Tax Giveaway Act - ALL S. 3317 Ending the Carried Interest Loophole Act - ALL H.R. 3749, Retail Revitalization Act of 2023 - ALL H.R. 5761 Opportunity Zones Transparency, Extension & Improvement Act, ALL

Client expense: $330,000 · Firm income: Not reported

"Carried Interest Fairness Act" and carried interest reform, including changes in holding period Energy efficiency and clean energy tax incentives, including the E-QUIP Act and Inflation Reduction Act, and regulatory implementation Like-Kind Exchanges (Sec. 1031) Completed contract method of accounting and condominium construction (Section 460(e) Fair Accounting for Condominium Construction Act (HR 4280) FIRPTA reform and Parity for Non-Traded REITS Act Net investment income tax and SECA liability Cost recovery, residential rental property and nonresidential property Low-income housing tax credit and the Affordable Housing Credit Improvement Act (S 1557 and HR 3238) Proposed and final tax regulations under section 897 and 892 REIT rules, including investments in related parties Retail Revitalization Act of 2023 (HR 3749) Cancellation of Indebtedness income (section 108) (HR 5580, Saving Our Mainstreet American Locations for Leisure and Shopping Act) Capital gains tax rate State and local tax deduction 20% deduction for pass-through business income (section 199A) and tax rules on pass-through income, including Senator Wyden pass-through reform discussion draft Taxing appreciated capital gains at death Opportunity Zone reform, reporting, and deadline extensions (HR 5761, Opportunity Zones Transparency, Extension and Improvement Act) Estate tax valuation discounts and rules for grantor trusts Revitalizing Downtowns Act and tax incentives for property conversions Passive Foreign Investment Company proposed tax regulations (REG-118250-20) Taxing unrealized gains annually - Administration's minimum tax proposal and Chairman Wyden proposal TCJA Permanency Act Business interest deductibility and section 163(j) Active loss limitation and section 461(l) S. 2518, Ending Tax Breaks for Massive Sovereign Wealth Funds Act S. 2224, Stop Predatory Investing Act.

Issues relating to economic development of distressed communities, including IRC section 1400Z, S.4065, H.R.7467, and H.R.5761.

Client expense: $110,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Issues relating to economic development of distressed communities, including IRC section 1400Z, S.4065, H.R.7467, and H.R.5761. Issues relating to non-compete agreements and their effects on economic dynamism, including S.220 and H.R.731. Issues relating to demographic trends, labor force issues and the availability of human capital, including immigration. Issues relating to inclusive wealth building and retirement security, including H.R.9462 and S.5271. Issues related to increasing technology and innovation, including H.R.4346.

Client expense: $110,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

"Carried Interest Fairness Act" and carried interest reform, including changes in holding period Energy efficiency and clean energy tax incentives, including the E-QUIP Act and Inflation Reduction Act, and regulatory implementation Like-Kind Exchanges (Sec. 1031) Completed contract method of accounting and condominium construction (Section 460(e) Fair Accounting for Condominium Construction Act (HR 4280) FIRPTA reform and Parity for Non-Traded REITS Act Net investment income tax and SECA liability Cost recovery, residential rental property and nonresidential property Low-income housing tax credit and the Affordable Housing Credit Improvement Act (S 1557 and HR 3238) Proposed and final tax regulations under section 897 and 892 REIT rules, including investments in related parties Retail Revitalization Act of 2023 (HR 3749) Cancellation of Indebtedness income (section 108) (HR 5580, Saving Our Mainstreet American Locations for Leisure and Shopping Act) Capital gains tax rate State and local tax deduction 20% deduction for pass-through business income (section 199A) and tax rules on pass-through income, including Senator Wyden pass-through reform discussion draft Taxing appreciated capital gains at death Opportunity Zone reform, reporting, and deadline extensions (HR 5761, Opportunity Zones Transparency, Extension and Improvement Act) Estate tax valuation discounts and rules for grantor trusts Revitalizing Downtowns Act and tax incentives for property conversions Passive Foreign Investment Company proposed tax regulations (REG-118250-20) Taxing unrealized gains annually - Administration's minimum tax proposal and Chairman Wyden proposal TCJA Permanency Act Business interest deductibility and section 163(j) Active loss limitation and section 461(l) S. 2518, Ending Tax Breaks for Massive Sovereign Wealth Funds Act S. 2224, Stop Predatory Investing Act.

Issues related to IRC section 1400Z. (H.R. 3937, H.R. 3906, H.R. 4055, H.R. 5761)

Client expense: Not reported · Firm income: $50,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE