Improving the Low Income Housing Tax Credit Rate Act

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). H.R. 1, 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 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. Also, asked that the Obama Administration not include this proposal in its forthcoming FY 2016 Budget. Expiring Tax Provisions H.R. 5771, Tax Increase Prevention Act of 2014. Section 112: Extension of temporary minimum low-income housing tax credit rate for non-Federally subsidized buildings. Section 113: Extension of military housing allowance exclusion for determining whether a tenant in certain counties is low-income. Section 115: Extension of New Markets Tax Credit. Section 125: Extension of Bonus Depreciation. Section 127: Extension of increased expensing limitations and treatment of certain real property as section 179 property. Section 156: Extension of Credit for Energy Efficient New Homes. Section 158: Extension of Energy Efficient Commercial Buildings deduction. 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. 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. Obama Administration's Fiscal Year 2015 Budget Revenue Proposal to Encourage Mixed Income Occupancy by Allowing Low-Income Housing Tax Credit-Supported Projects to Elect a Criterion Employing a Restriction on Average Income We also considered proposals to expand the credit, such as 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. Foreign Investment in Real Property Tax Act (FIRPTA) H.R. 2870, Real Estate Investment and Jobs Act of 2013, 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, Real Estate Investment and Jobs Act of 2013, 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. Amendment filed by Senators Menendez and Enzi to draft legislation before the Senate Finance Committee, Preserving Americas Transit and Highways Act, which would remove the tax penalty FIRPTA imposes on foreign pension funds investing in U.S. real estate and increase the ownership stake a foreign investor can take in a publicly traded company whose assets consist largely of U.S. real property without triggering FIRPTA. H.R. 5487, Real Estate Investment and Jobs Act of 2014, 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 interests, all provisions. 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.

Client expense: $430,500 · Firm income: Not reported

Government targets: Army, Dept of (Corps of Engineers), Energy, Dept of, Environmental Protection Agency (EPA), Equal Employment Opportunity Commission (EEOC), Federal Communications Commission (FCC), Federal Housing Finance Agency (FHFA), Federal Reserve System, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Labor, Dept of (DOL), Natl Economic Council (NEC), Office of Management & Budget (OMB), President of the U.S., SENATE, Small Business Administration (SBA), Social Security Administration (SSA), Treasury, Dept of, U.S. Postal Service (USPS)

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.

S. 1133 New Markets Tax Credit Extension Act of 2013 S. 1442, Improving the Low Income Housing Tax Credit Rate Act S. 2003, A bill to amend the Internal Revenue Code of 1986 to extend the energy credit for certain property under constructionS. 2059, A bill to amend the Internal Revenue Code of 1986 to allow a credit for the purchase of heating and cooling equipment which meets the Energy Star program requirements and is used in certain high-cost energy communities, and for other purposes S. 2179, A bill to amend title 38, United States Code, to waive the minimum period of continuous active duty in the Armed Forces for receipt of benefits for homeless veterans, to authorize the Secretary of Veterans Affairs to furnish benefits for homeless veterans to homeless veterans with discharges or releases from service in the Armed Forces under other than honorable conditions, and for other purposes S. 2203, A bill to amend the Internal Revenue Code of 1986 to permanently extend the tax treatment for certain build America bonds, and for other purposes S. 2212, A bill to amend the Consumer Financial Protection Act of 2010 to strengthen the review authority of the Financial Stability Oversight Council of regulations issued by the Bureau of Consumer Financial Protection, and for other purposes S. 2233, National Disaster Tax Relief Act of 2014 S. 2388, A bill to amend the Internal Revenue Code of 1986 to modify the depreciation recovery period for energy-efficient cool roof systems, and for other purposes S. 2634, National Disaster Tax Relief Act of 2014

Client expense: $155,182 · 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; (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.

S. 1133, New Markets Tax Credit Extension Act of 2013 S. 1442, Improving the Low Income Housing Tax Credit Rate Act S. 2003, A bill to amend the Internal Revenue Code of 1986 to extend the energy credit for certain property under constructionS. 2059, A bill to amend the Internal Revenue Code of 1986 to allow a credit for the purchase of heating and cooling equipment which meets the Energy Star program requirements and is used in certain high-cost energy communities, and for other purposes S. 2179, A bill to amend title 38, United States Code, to waive the minimum period of continuous active duty in the Armed Forces for receipt of benefits for homeless veterans, to authorize the Secretary of Veterans Affairs to furnish benefits for homeless veterans to homeless veterans with discharges or releases from service in the Armed Forces under other than honorable conditions, and for other purposes S. 2203, A bill to amend the Internal Revenue Code of 1986 to permanently extend the tax treatment for certain build America bonds, and for other purposes S. 2212, A bill to amend the Consumer Financial Protection Act of 2010 to strengthen the review authority of the Financial Stability Oversight Council of regulations issued by the Bureau of Consumer Financial Protection, and for other purposes S. 2233, National Disaster Tax Relief Act of 2014 S. 2388, A bill to amend the Internal Revenue Code of 1986 to modify the depreciation recovery period for energy-efficient cool roof systems, and for other purposes

Client expense: $155,182 · 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; (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

S.1442, Improving the Low Income Housing Tax Credit Rate Act. Support.

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

Government targets: HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), SENATE

Low Income Housing Tax Credit (S. 1442)

Client expense: $140,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), SENATE

Department of Housing and Urban Development Appropriations and Budget; Financial Services Authorization; Banking Committee Authorizations; Low Income Housing Tax Credits (S. 1442); General LISC business/information

Client expense: $140,000 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), 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.

S.1442, Improving the Low Income Housing Tax Credit Rate Act. Support.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Draft legislation authored by House Ways and Means Committee Chairman Dave Camp in 2013-Tax Reform Act of 2013: Title IITax Reform for Businesses, Subtitle COption 1 Passthrough Entities, all provisions (i.e., Part 1Option 1 S Corporations and Part 2Option 1 Partnerships), and Subtitle COption 2 Unified Rules for Passthroughs, all provisionsTax Reform- Comphrehensive approach to tax reform and to avoid enacting reform for C corporations at the expense of flow-through entities. 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 Senate Committee on Finance Chairman's Staff Discussion Draft to Reform Certain Energy Tax Provisions. Section 2. Clean Energy Investment Credit. S. 727- (112th Congress), The Bipartisan Tax Fairness and Simplification Act of 2011: Section 204(d): Depreciation of Tangible Property in Excess of Alternative Depreciation System. 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 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. 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. Proposals to expand the credit, such as one to increase the program by 50%.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. 3591- Commercial Building Modernization Act from 112th Congress 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. Extension of Expiring Tax Provisions: providing for the: (1) flat 9 percent tax credit for the Low-Income Housing Tax Credit; (2) Energy Efficient Commercial Building Tax Deduction; (3) Energy Efficient New Homes Tax Credit; (4) New Markets Tax Credit; (5) expensing of brownfield remediation costs; (6) election to expense certain qualified real property; and (7) 15-year depreciation of leasehold improvements. 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.

Proposals impacting the low-income housing credit, including S. 1442, Improving the Low Income Housing Tax Credit Rate Act and Rep. Camp's tax reform discussion draft.

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).Advocated for increasing the 302(b) allocation to the House and Senate Appropriations Subcommittees on Transportation, Housing and Urban Development, and Related Agencies (THUD) to the highest possible level in fiscal year (FY) 2015. [Allocations not available during the reporting period]. Subcommittee Allocations FY 2014 Discretionary Spending, January13, 2014; all provisions concerning the 302(b) allocation for the Transportation-Housing and Urban Development and Related Agencies Subcommittees. House Appropriations Committee "FY 2014 Report on the Suballocation of the Budget Allocations." All provisions concerning the 302(b) allocation for the Transportation-Housing and Urban Development and Related Agencies Subcommittee. Senate Appropriations Committee, "FY14 Subcommittee Allocations;" All provisions concerning the 302(b) allocation for the Transportation-Housing and Urban Development and Related Agencies Subcommittee. HR 3457: Consolidated Appropriations Act, 2014. Making consolidated appropriations for the fiscal year ending September 30, 2014, and for other purposes. DIVISION A-AGRICULTURE, RURAL DEVELOPMENT, FOOD AND DRUG ADMINISTRATION, AND RELATED AGENCIES APPROPRIATIONS ACT, 2014, Title III Rural Development Programs; all provisions under Rural Housing Service concerning affordable multifamily housing programs. DIVISION L-TRANSPORTATION, HOUSING AND URBAN DEVELOPMENT, AND RELATED AGENCIES APPROPRIATIONS ACT, 2014 Title II--Department of Housing and Urban Development; all provisions concerning affordable multifamily housing & rental assistance programs. Explanatory Statement Submitted By Mr. Rogers of Kentucky, Chairman of the House Committee on Appropriations Regarding the House Amendment to the Senate Amendment on H.R. 3547 Consolidated Appropriations Act, 2014: DIVISION A-AGRICULTURE, RURAL DEVELOPMENT, FOOD AND DRUG ADMINISTRATION, AND RELATED AGENCIES APPROPRIATIONS ACT 2014,TITLE III RURAL DEVELOPMENT PROGRAMS; all provisions concerning the Rental Assistance Program. HR 2410: Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2014. Making appropriations for Agriculture, Rural Development, Food and Drug Administration, and Related Agencies programs for the fiscal year ending September 30, 2014, and for other purposes. TITLE III RURAL DEVELOPMENT PROGRAMS - all provisions under Rural Housing Service related to affordable multifamily housing programs. S. 1244: Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2014. Making appropriations for Agriculture, Rural Development, Food and Drug Administration, and Related Agencies programs for the fiscal year ending September 30, 2014, and for other purposes. TITLE III -RURAL DEVELOPMENT PROGRAMS - all provisions under Rural Housing Service related to affordable multifamily housing & rental assistance programs. HR 2610: Transportation, Housing and Urban Development, and Related Agencies Appropriations Act, 2014. Making appropriations for the Departments of Transportation, and Housing and Urban Development, and related agencies for the fiscal year ending September 30, 2014, and for other purposes. TITLE II DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT - all provisions related to affordable multifamily housing & rental assistance programs. S.1243: Transportation, Housing and Urban Development, and Related Agencies Appropriations Act, 2014. Making appropriations for the Departments of Transportation, and Housing and Urban Development, and related agencies for the fiscal year ending September 30, 2014, and for other purposes. TITLE II DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT - all provisions related to affordable multifamily housing & rental assistance programs. 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.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.] 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 News Release "FHFA Seeks Public Input on Reducing Fannie Mae and Freddie Mac Multifamily Businesses," August 9, 2013; all provisions. Federal Housing Finance Agency "Options for Reducing Fannie Mae and Freddie Macs Multifamily Businesses" Released by FHFA for Public Input, August 9, 2013; all provisions. Federal Housing Finance Agency, "Preparing a Foundation for a More Efficient and Effective Housing Finance System, Strategic Plan: Fiscal Years 2013-2017," all provisions which affect GSE's multifamily 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, "Multifamily Transformation Announces Three Key Changes; November, 26 2013; all provisions. HUD Press Release HUD No. 13-054 "HUD Announces Major Restructuring of Field Offices," April 24, 2013; all provisions. HUD [Docket No. FR5698N01] "Notice of Intent To Close 16 Field Offices" Friday, April 26, 2013; 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. 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; Chapter 9, all provisions of 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. Offered preliminary feedback on HUD Civil Money Penalties Pilot for Owners/Properties with Failing REAC Scores. HUD Preparing for REAC Inspections (Guidance for MultiFamily and Public Housing Properties);" all provisions.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. Advocated for retaining the Low Income Housing Tax Credit (LIHTC) program as part of comprehenisive tax reform efforts. 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. Advocated for policies to promote long-term sustainablity and financial solvency of Low Income Housing Tax Credit Properties. 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). USDA-RHS Proposed Rule [RIN 0575AC96] "Rural Development Voucher Program," August 14, 2013; 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.

FY 2014 Appropriations, FY 2014-2015 Budget, CDBG, HOME Program, McKinney Vento Continuum of Care, S. 1442 Improving the Low Income Housing Tax Credit Rate, HUD Proposed Rule on Affirmatively Furthering Fair Housing (Docket No. FR-5173-P-01), Low-Income Housing Tax Credit Extension

Client expense: Not reported · Firm income: $10,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE, White House Office

Proposals impacting the low-income housing credit, including S. 1442, Improving the Low Income Housing Tax Credit Rate Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Tax reform: We advocated for the following priorities as Congress considers tax reform: We asked that Congress take a comprehensive approach to tax reform and not enact reform for C corporations at the expense of flow-through entities, including partnerships, S Corporations, and LLCs. We also asked policymakers not to tax flow-through entities with revenues over certain thresholds as C Corporations or to pass legislation that would disadvantage real estate relative to other industries.We also favor 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 that feature a $5 million exemption, 40 percent top rate, and retention of stepped-up basis; (5) Section 1031 like-kind exchanges; and (6) the deductibility of state and local real estate taxes. We also 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). Finally, we oppose: (1)increasing the 27.5-year depreciation period for multifamily buildings and (2) increasing taxes applicable to depreciation recapture. We conducted lobbying activities with regard to the following tax reform proposals: - 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 - Senate Committee on Finance Chairman's Staff Discussion Draft to Reform Certain Energy Tax Provisions. Section 2. Clean Energy Investment Credit. Carried Interest: We oppose changes to current law as part of any legislation, including: 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: - We support efforts to make permanent the 9 percent tax credit for the Low-Income Housing Tax Credit (LIHTC) and to extend the same policy to 4 percent LIHTCs for acquisition. We specifically support S. 1442, Improving the Low Income Housing Tax Credit Rate Act (all provisions) that would put this policy into place. - We also urged Congress to preserve the LIHTC and tax-exempt private activity housing bonds as part of any tax reform efforts. - Although no bill is pending, we asked Congress to 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. No specific legislation supported yet this Congress, but we supported efforts to amend the Internal Revenue Code to improve and extend the deduction for new and existing energy efficient commercial buildings (S. 3591, Commercial Building Modernization Act from 112th Congress, 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. IRS Final Rule (TD 9636) and temporary (TD 9564) and proposed rules (REG-110732-13) and REG-168745-03) regarding the deduction and capitalization of expenditures related to tangible property under Internal Revenue Code Sections 162(a) and 263(a). We asked that the temporary and proposed regulations be made more administrable through: (1) addition of bright-line examples; (2) expansion of de minimis rules; and (3) treatment of multiple buildings in a development as a single unit of property.

Budget of the United States Government, Fiscal Year 2014; 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).PL 112-25: Budget Control Act of 2011. A bill to control the budget; All provisions in Title I TEN-YEAR DISCRETIONARY CAPS WITH SEQUESTER, Sections 101,102,105,106 & Title III Section 302 Enforcement of budget goal related to discretionary spending levels as part of deficit reduction requirements (which could reduce funding for important U.S. HUD and USDA affordable multifamily housing programs). H.J.RES.59 [Public Law No: 113-67] Making continuing appropriations for fiscal year 2014, and for other purposes. Bipartisan Budget Act of 2013, DIVISION A-- Bipartisan Budget Agreement, Bipartisan Budget Act of 2013, all provisions of Title I which affect sequestion, discretionary spending caps and congressional committee budget allocations (which affect funding of federal multifamily housing programs). H.CON.RES.25:Establishing the budget for the United States Government for fiscal year 2014 and setting forth appropriate budgetary levels for fiscal years 2015 through 2023. All provisions which affect funding levels for affordable housing programs in TITLE I--Recommended Levels and Amounts; all provisions in TITLE II, SEC. 201. Reconciliation in the Senate which could affect the Low Income Housing Tax Credit tax expenditure; urged replacement of sequestration [not included]. S.CON.RES.8: Concurrent Resolution on the Budget for Fiscal Year 2014. The concurrent resolution on the budget for fiscal year 2014 and this resolution sets forth the appropriate budgetary levels for fiscal years 2013 and 2015 through 2023. All provisions which affect funding levels for affordable housing programs in TITLE I--Recommended Levels and Amounts; all provisions in TITLE II, SEC. 201. Reconciliation in the Senate which could affect the Low Income Housing Tax Credit tax expenditure; and all provisions regarding sequestration in TITLE III Sec. 301. Deficit-neutral reserve fund to replace sequestration & TITLE IV Subtitle A, Sec. 403. Adjustments for sequestration or sequestration replacement. House Appropriations Committee "FY 2014 Report on the Suballocation of the Budget Allocations." All provisions concerning the 302(b) allocation for the Transportation-Housing and Urban Development and Related Agencies Subcommittee. Senate Appropriations Committee, "FY14 Subcommittee Allocations." All provisions concerning the 302(b) allocation for the Transportation-Housing and Urban Development and Related Agencies Subcommittee. H.R.2775: Continuing Appropriations Act, 2014. Making continuing appropriations for the fiscal year ending September 30, 2014, and for other purposes. All provisions in Section 101, Section 103 and Section 106 related to funding and administration of HUD and USDA-RHS federal multifamily housing programs. H.J.RES.59: Continuing Appropriations Resolution, 2014. Making continuing appropriations for fiscal year 2014, and for other purposes. All provisions of Section 101, 103 and 106 related to funding & administration of HUD and USDA-RHS multifamily housing programs. [Requested an anomaly for USDA-RHS Rural Rental Assistance (RA) & authority for RHS to make retroactive FY 13 RA payments to owners-not included. Requested that language from S. Rept.113-46 for S.1244, which directs USDA to submit a report that includes a revised estimate of RA needs in FY 2014, also be included with any report /explanatory document for the FY 2014 Continuing Resolution-not included.] HR 2410: Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2014. Making appropriations for Agriculture, Rural Development, Food and Drug Administration, and Related Agencies programs for the fiscal year ending September 30, 2014, and for other purposes. TITLE III RURAL DEVELOPMENT PROGRAMS - all provisions under Rural Housing Service related to affordable multifamily housing programs. S. 1244: Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2014. Making appropriations for Agriculture, Rural Development, Food and Drug Administration, and Related Agencies programs for the fiscal year ending September 30, 2014, and for other purposes. TITLE III RURAL DEVELOPMENT PROGRAMS - all provisions under Rural Housing Service related to affordable multifamily housing & rental assistance programs.S. Rept. 113-46:(to accompany S. 1244) AGRICULTURE, RURAL DEVELOPMENT, FOOD AND DRUG ADMINISTRATION, AND RELATED AGENCIES APPROPRIATIONS BILL, 2014. All provisions of Committee Recommendation in Title III, Rental Assistance, directing the Secretary of USDA to submit a report on Rental Assistance (RA) which includes a revised estimate of RA needs in FY 2014, to cover the original estimate of expiring units and those not renewed in FY 2013. [Requested inclusion on the FY 14 Continuing Resolution (H.J.Res. 59) or Final FY 14 Agriculture Appropriations bill (S.1244/HR2410).] HR 2610: Transportation, Housing and Urban Development, and Related Agencies Appropriations Act, 2014. Making appropriations for the Departments of Transportation, and Housing and Urban Development, and related agencies for the fiscal year ending September 30, 2014, and for other purposes. TITLE II DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT - all provisions related to affordable multifamily housing & rental assistance programs. S.1243: Transportation, Housing and Urban Development, and Related Agencies Appropriations Act, 2014. Making appropriations for the Departments of Transportation, and Housing and Urban Development, and related agencies for the fiscal year ending September 30, 2014, and for other purposes. TITLE II DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT - all provisions related to affordable multifamily housing & rental assistance programs. 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. Public Law 112-55: Consolidated and Further Continuing Appropriations Act, 2012, DIVISION CTRANSPORTATION, HOUSING AND URBAN DEVELOPMENT, AND RELATED AGENCIES Appropriations Act, 2012, TITLE II DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT; all provisions of RENTAL ASSISTANCE DEMONSTRATION which allow projects funded under the Rent Supplement, Section 236 Rental Assistance Payment, or Section 8 Moderate Rehabilitation to convert tenant protection vouchers to project-based vouchers upon contract termination. 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. 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 Proposed Rule, "Affirmatively Furthering Fair Housing," [Docket No. FR5173P01], July 19, 2013; all provisions. HUD's Final Rule, "Implementation of the Fair Housing Acts Discriminatory Effects Standard," [Docket No. FR5508F02] February 15, 2013; all provisions.Federal Housing Finance Agency News Release "FHFA Seeks Public Input on Reducing Fannie Mae and Freddie Mac Multifamily Businesses," August 9, 2013; all provisions. Federal Housing Finance Agency "Options for Reducing Fannie Mae and Freddie Macs Multifamily Businesses" Released by FHFA for Public Input, August 9, 2013; all provisions. Offered preliminary feedback on HUD Civil Money Penalties Pilot for Owners/Properties with Failing REAC Scores. HUD Initiative "Transforming Multifamily for the 21st Century"; all provisions. HUD, "Multifamily Transformation Announces Three Key Changes; November, 26 2013; all provisions. HUD Press Release HUD No. 13-054 "HUD Announces Major Restructuring of Field Offices," April 24, 2013; all provisions. HUD [Docket No. FR5698N01] "Notice of Intent To Close 16 Field Offices" Friday, April 26, 2013; all provisions. 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). 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 "Revising Handbook 4350.1, Phase I, Units and Topics," April 8, 2013; 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 Transmittal for Handbook No: 4350.3 "Occupancy Requirements of Subsidized Multifamily Housing Programs" REV-1,CHG-4, August 7, 2013; all provisions. HUD Revised Transmittal for Handbook No: 4350.3 REV-1,CHG-4, November 27, 2013; all provisions. HUD Office of Housing Multifamily Housing Programs Memorandum "Suspension of the Requirements Contained in Sections 9-23, 9-24, and 9-25 of the Section 8 Renewal Policy Guide," September 7, 2012; all provisions (regarding new appraisal procedures for benchmarking rents in rent comparability studies). HUD [Docket No. FR5725N02] Notice "Final Fair Market Rents for the Housing Choice Voucher Program and Moderate Rehabilitation Single Room Occupancy Program Fiscal Year 2014," October 3, 2013; all provisions. 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 [Docket No: FR5667N02] "Announcement of Issuance by HUD of Notice of Senior Preservation Rental Assistance Contracts Award Process and Solicitation of Applications," July 3, 2013; all provisions. 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 "Guidance on Housing Notice H 2013-17, Updated Requirements for Prepayment and Refinance of Section 202 Direct Loans," June 26, 2013; all provisions. HUD Preparing for REAC Inspections (Guidance for MultiFamily and Public Housing Properties);" all provisions. HUD Notice H 2012-5, "Guidelines on Addressing Infestations in HUD-insured and Assisted Multifamily Housing," April 23, 2012; all provisions. 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. Advocated for retaining the Low Income Housing Tax Credit (LIHTC) program as part of comprehenisive tax reform efforts. IRS Notice 2013-22, "Public Comment Invited on Recommendations for 2013-2014 Guidance Priority List," March 22, 2013; 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. IRS Notice 2012-18 Physical Inspections Pilot Program February 9, 2012; all provisions [LIHTC compliance requirements]. Advocated for policies to promote long-term sustainablity and financial solvency of Low Income Housing Tax Credit Properties. 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. Offered prelimiary input to USDA-RHS regarding the RHS' plans to develop a pest management policy and best practices; our input focused on application to multifamily properties. 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). USDA-RHS Proposed Rule [RIN 0575AC96] "Rural Development Voucher Program," August 14, 2013; all provisions.Advocated for USDA-RHS to request an anomoly on the FY 14 Continuing Resolution for FY 13 Rental Assistance Payments & to request legislative authority to retroactively pay owners affected by the FY 13 Rental Assistance on the Continuing Resolutation or final FY 14 Agriculture Appropriations bill. 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.

FY 2014 Appropriations, CDBG, HOME Program, McKinney Vento Continuum of Care, S. 1442 Improving the Low Income Housing Tax Credit Rate, HUD Proposed Rule on Affirmatively Furthering Fair Housing (Docket No. FR-5173-P-01), Low-Income Housing Tax Credit Extension

Client expense: Not reported · Firm income: $10,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S.1442, Improving the Low Income Housing Tax Credit Rate Act. Support.

Client expense: Not reported · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S.1442, Improving the Low Income Housing Tax Credit Rate Act. S.1217, Housing Finance Reform and Taxpayer Protection Act of 2013. Budget/Appropriations for HUD Section 202 Housing for the Elderly Program. Policy impacting senior citizens.

Client expense: Not reported · Firm income: Not reported

S.1442, Improving the Low Income Housing Tax Credit Rate Act. S.1217, Housing Finance Reform and Taxpayer Protection Act of 2013. Budget/Appropriations for HUD Section 202 Housing for the Elderly Program. Policy impacting senior citizens.

Client expense: Not reported · Firm income: Not reported

Tax reform: We asked that Congress take a comprehensive approach to tax reform and not enact reform for C corporations at the expense of flow-thru entities, including partnerships, S Corporations, and LLCs. We also asked policymakers not to tax flow-through entities with revenues over certain thresholds as C corporations or to pass legislation that would disadvantage real estate relative to other industries.We also favor maintaining: (1) the current-law 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 that feature a $5 million exemption, 40 percent top rate, and retention of stepped-up basis rules; (5) the current-law rules regarding Section 1031 like-kind exchanges; (6) the 27.5 year depreciation period for multifamily real estate; and (7) the deductibility of state and local real estate taxes. Additionally, we signed a real estate industry letter on tax reform. This letter called on Congress to foster a tax code that promotes: (1) capital formation (i.e., preserving reduced rates on capital gains, preserving capital gains treatment for carried interest, maintaining the tax exclusion for the sale of a principal residence, and stimulating inbound foreign investment); (2) cost recovery (i.e., decreasing depreciable lives of real estate assets and retaining stepped-up basis on inherited assets); (3) retaining the full deductibility of business interest; (4) a vibrant housing sector by maintaining the Low-Income Housing Tax Credit and the deductibility of mortgage interest and real property taxes; (5) retaining like-kind exchanges; and (6) maintaining entity choice and a single level of tax for pass-through entities. Carried Interest. We oppose changes to current law as part of any legislation, including: 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, and Section 603. Special Rules for Partners Providing Investment Management Services to Partnerships. Low-Income Housing Tax Credit: We support efforts to make permanent the 9 percent tax credit for the Low-Income Housing Tax Credit (LIHTC) and to extend the same policy to 4 percent LIHTCs for acquisition. We specifically support S. 1442, Improving the Low Income Housing Tax Credit Rate Act, all provisions, that would put this policy into place. We also urged Congress to preserve the Low-Income Housing Tax Credit and tax-exempt private activity housing bonds as part of any tax reform effort. Although no bill is pending, we asked Congress to support making the Low-Income Housing Tax Credit 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. No specific legislation supported yet this Congress, but we supported efforts to amend the Internal Revenue Code of 1986 to improve and extend the deduction for new and existing energy efficient commercial buildings (S. 3591, Commercial Building Modernization Act from 112th Congress, all provisions). 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. IRS Final Rule (TD 9636) and temporary (T.D. 9564) and proposed rules (REG-110732-13 and REG-168745-03) regarding the deduction and capitalization of expenditures related to tangible property under Internal Revenue Code Sections 162(a) and 263(a). Asked that temporary and proposed regulations be made more administrable through: (1) addition of bright-line examples; (2) expansion of de minimis rules; and (3) treatment of multiple buildings in a development as a single unit of property.

Proposals impacting the low-income housing credit, including S. 1442, Improving the Low Income Housing Tax Credit Rate Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Budget of the United States Government, Fiscal Year 2014; 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).PL 112-25: Budget Control Act of 2011. A bill to control the budget; All provisions in Title I TEN-YEAR DISCRETIONARY CAPS WITH SEQUESTER, Sections 101,102,105,106 & Title III Section 302 Enforcement of budget goal related to discretionary spending levels as part of deficit reduction requirements (which could reduce funding for important U.S. HUD and USDA affordable multifamily housing programs). H.CON.RES.25:Establishing the budget for the United States Government for fiscal year 2014 and setting forth appropriate budgetary levels for fiscal years 2015 through 2023. All provisions which affect funding levels for affordable housing programs in TITLE I--Recommended Levels and Amounts; all provisions in TITLE II, SEC. 201. Reconciliation in the Senate which could affect the Low Income Housing Tax Credit tax expenditure; urged replacement of sequestration [not included]. S.CON.RES.8: Concurrent Resolution on the Budget for Fiscal Year 2014. The concurrent resolution on the budget for fiscal year 2014 and this resolution sets forth the appropriate budgetary levels for fiscal years 2013 and 2015 through 2023. All provisions which affect funding levels for affordable housing programs in TITLE I--Recommended Levels and Amounts; all provisions in TITLE II, SEC. 201. Reconciliation in the Senate which could affect the Low Income Housing Tax Credit tax expenditure; and all provisions regarding sequestration in TITLE III Sec. 301. Deficit-neutral reserve fund to replace sequestration & TITLE IV Subtitle A, Sec. 403. Adjustments for sequestration or sequestration replacement. HR 2410: Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2014. Making appropriations for Agriculture, Rural Development, Food and Drug Administration, and Related Agencies programs for the fiscal year ending September 30, 2014, and for other purposes. TITLE III RURAL DEVELOPMENT PROGRAMS - all provisions under Rural Housing Service related to affordable multifamily housing programs. S. 1244: Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2014. Making appropriations for Agriculture, Rural Development, Food and Drug Administration, and Related Agencies programs for the fiscal year ending September 30, 2014, and for other purposes. TITLE III RURAL DEVELOPMENT PROGRAMS - all provisions under Rural Housing Service related to affordable multifamily housing & rental assistance programs. S. Rept. 113-46:(to accompany S. 1244) AGRICULTURE, RURAL DEVELOPMENT, FOOD AND DRUG ADMINISTRATION, AND RELATED AGENCIES APPROPRIATIONS BILL, 2014. All provisions of Committee Recommendation in Title III, Rental Assistance, directing the Secretary of USDA to submit a report on Rental Assistance (RA) which includes a revised estimate of RA needs in FY 2014, to cover the original estimate of expiring units and those not renewed in FY 2013. [Requested inclusion on the FY 14 Continuing Resolution (H.J.Res. 59) or Final FY 14 Agriculture Appropriations bill (S.1244/HR2410).] HR 2610: Transportation, Housing and Urban Development, and Related Agencies Appropriations Act, 2014. Making appropriations for the Departments of Transportation, and Housing and Urban Development, and related agencies for the fiscal year ending September 30, 2014, and for other purposes. TITLE II DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT - all provisions related to affordable multifamily housing & rental assistance programs. Draft Amendment to HR 2610 from Rep. Scott Garrett Amdt to prohibit funding for implementation, enforcement or administration of HUD's Final Rule, "Implementation of the Fair Housing Acts Discriminatory Effects Standard," [Docket No. FR5508F02] February 15, 2013; all provisions. [Not introduced during reporting period.] S.1243: Transportation, Housing and Urban Development, and Related Agencies Appropriations Act, 2014. Making appropriations for the Departments of Transportation, and Housing and Urban Development, and related agencies for the fiscal year ending September 30, 2014, and for other purposes. TITLE II DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT - all provisions related to affordable multifamily housing & rental assistance programs.H.J.RES.59: Continuing Appropriations Resolution, 2014. Making continuing appropriations for fiscal year 2014, and for other purposes. All provisions of Section 101, 103 and 106 related to funding & administration of HUD and USDA-RHS multifamily housing programs. [Requested an anomaly for USDA-RHS Rural Rental Assistance (RA) & authority for RHS to make retroactive FY 13 RA payments to owners-not included. Requested that language from S. Rept.113-46 for S.1244, which directs USDA to submit a report that includes a revised estimate of RA needs in FY 2014, also be included with any report /explanatory document for the FY 2014 Continuing Resolution-not included.] S. 766: A bill to amend section 520 of the Housing Act of 1949 to revise the census data and population requirements for areas to be considered as rural areas for purposes of such Act; all provisions [definition of rural area determines eligiblity for USDA-RHS housing programs]. S.954: Agriculture Reform, Food, and Jobs Act of 2013;TITLE VI--RURAL DEVELOPMENT, all provisions of Sec. 6202 Definition of rural area for purposes of the Housing Act of 1949 [definition of rural area determines eligiblity for USDA-RHS housing programs]. S. 1376: The FHA Solvency Act of 2013. A bill to improve the Federal Housing Administration and to ensure the solvency of the Mutual Mortgage Insurance Fund, and for other purposes; all provisions of Section 7. Ensuring Adequate Capital Levels in the Mutual Mortgage Insurance Fund. Draft amendment to S. 1376 by Senator David Vitter to create a capital reserve requirement for the FHA multi-family program; all provisions [not included]. 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. Public Law 112-55: Consolidated and Further Continuing Appropriations Act, 2012, DIVISION CTRANSPORTATION, HOUSING AND URBAN DEVELOPMENT, AND RELATED AGENCIES Appropriations Act, 2012, TITLE II DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT; all provisions of RENTAL ASSISTANCE DEMONSTRATION which allow projects funded under the Rent Supplement, Section 236 Rental Assistance Payment, or Section 8 Moderate Rehabilitation to convert tenant protection vouchers to project-based vouchers upon contract termination. 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. 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 Proposed Rule, "Affirmatively Furthering Fair Housing," [Docket No. FR5173P01], July 19, 2013; all provisions. HUD's Final Rule, "Implementation of the Fair Housing Acts Discriminatory Effects Standard," [Docket No. FR5508F02] February 15, 2013; all provisions. HUD Press Release HUD No. 13-054 "HUD Announces Major Restructuring of Field Offices," April 24, 2013; all provisions. HUD Initiative "Transforming Multifamily for the 21st Century"; all provisions. HUD [Docket No. FR5698N01] "Notice of Intent To Close 16 Field Offices" Friday, April 26, 2013; all provisions. Offered preliminary feedback to HUD on potential demonstration program to test methodologies for achieving long-run cost savings in HUDs insured and assisted housing portfolios for high performing owner/sponsors to take advantage of less prescriptive oversight & a potential share of cost savings when they agree to fold groups of affordable housing properties into single portfolios that will be managed as one unit. (Demo program not formally proposed during reporting period.) 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). 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. Government Accountability Office "Decision in the Matter of Assisted Housing Services Corporation; North Tampa Housing Development Corporation; The Jefferson County Assisted Housing Corporation; National Housing Compliance; Southwest Housing Compliance Corporation; CMS Contract Management Services and the Housing Authority of the City of Bremerton; Massachusetts Housing Finance Agency," File: B-406738; B-406738.2; B-406738.3; B-406738.4; B-406738.5; B-406738.6; B-406738.7; B-406738.8. August 15, 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 "Revising Handbook 4350.1, Phase I, Units and Topics," April 8, 2013; 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 Proposed Rule [Docket No. FR5586P01, RIN 2501AD60] "Pet Ownership for the Elderly or Persons With Disabilities in Multifamily Rental Housing; Accumulation of Deposits for Costs Attributable to Pets," May 24, 2013; all provisions. HUD Transmittal for Handbook No: 4350.3 "Occupancy Requirements of Subsidized Multifamily Housing Programs" REV-1,CHG-4, August 7, 2013; all provisions. HUD Office of Housing Multifamily Housing Programs Memorandum "Suspension of the Requirements Contained in Sections 9-23, 9-24, and 9-25 of the Section 8 Renewal Policy Guide," September 7, 2012; all provisions (regarding new appraisal procedures for benchmarking rents in rent comparability studies). 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 [Docket No: FR5667N02] "Announcement of Issuance by HUD of Notice of Senior Preservation Rental Assistance Contracts Award Process and Solicitation of Applications," July 3, 2013; all provisions. HUD [[Docket No: FR-5667-N-02] "Notice of Senior Preservation Rental Assistance Contracts Award Process," June 28, 2013; all provisions. 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 "Guidance on Housing Notice H 2013-17, Updated Requirements for Prepayment and Refinance of Section 202 Direct Loans," June 26, 2013; all provisions. HUD Final Notice [Docket No. FR5526N02] Public Housing Assessment System (PHAS): Physical Condition Scoring Notice and Revised Dictionary of Deficiency Definitions, August 9, 2012; all provisions. HUD Preparing for REAC Inspections (Guidance for MultiFamily and Public Housing Properties);" all provisions. HUD Notice H 2012-5, "Guidelines on Addressing Infestations in HUD-insured and Assisted Multifamily Housing," April 23, 2012; all provisions.HUD [Docket No. FR5725-N-01] Notice "Proposed Fair Market Rents for the Housing Choice Voucher Program and Moderate Rehabilitation Single Room Occupancy Program and Other Programs Fiscal Year 2014," August 5, 2013; all provisions. 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. Advocated for retaining the Low Income Housing Tax Credit (LIHTC) program and New Markets Tax Credit as part of comprehenisive tax reform efforts. IRS Notice 2013-22, "Public Comment Invited on Recommendations for 2013-2014 Guidance Priority List," March 22, 2013; 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. IRS Notice 2012-18 Physical Inspections Pilot Program February 9, 2012; all provisions [LIHTC compliance requirements]. Advocated for policies to promote long-term sustainablity and financial solvency of Low Income Housing Tax Credit Properties. USDA-RHS [RIN 0575AC93] Proposed Rule, "Civil Monetary Penalties," January 4, 2013; all provisions. Offered prelimiary input to USDA-RHS regarding the RHS' plans to develop a pest management policy and best practices; our input focused on application to multifamily properties. USDA-Rural Development (RD) Procedure Notice 458, September 24, 2012; RD Handbook Changes INSERT RD HB-2-3560 Chapter 3 (Revision to Attachment 3-F to reflect no change to the Fiscal Year 2013 Management Fee). Advocated for increased management fees in FY 2014 for multifamily properties subject to USDA-RD regulations. Advocated for USDA-RHS to request an anomoly on the FY 14 Continuing Resolution for FY 13 Rental Assistance Payments & to request legislative authority to retroactively pay owners affected by the FY 13 Rental Assistance on the Continuing Resolutation or final FY 14 Agriculture Appropriations bill. 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.

FY 2014 Appropriations, CDBG, HOME Program, McKinney Vento Continuum of Care, S. 1442 Improving the Low Income Housing Tax Credit Rate Act, HUD Proposed Rule on Affirmatively Furthering Fair Housing (Docket No. FR-5173-P-01)

Client expense: Not reported · Firm income: $10,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE