Affordable Housing Credit Improvement Act of 2016

S. 2962, Affordable Housing Credit Improvement Act of 2016, draft legislation on energy tax incentives

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

Government targets: Army, Dept of (Other), Council on Environmental Quality (CEQ), Energy, Dept of, Environmental Protection Agency (EPA), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, SENATE

S. 2962, Affordable Housing Credit Improvement Act of 2016; draft legislation on energy tax incentives

Client expense: $20,000 · Firm income: Not reported

Government targets: Army, Dept of (Other), Council on Environmental Quality (CEQ), Defense, Dept of (DOD), Energy, Dept of, Environmental Protection Agency (EPA), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, SENATE

Support continued tax-exempt status for charitable organizations and tax incentives for charitable giving. Support S. 2962, the Affordable Housing Credit Improvement Act, to increase states' Low Income Housing Tax Credit allocations by 50% over a five-year period, allow for income averaging in the LIHTC program, and make the 4% tax credit rate floor permanent for acquisition and bond-financed projects. Support S. 2750, the CHARITY Act, which would allow more flexibility for tax-free rollovers of IRA funds to charitable organizations. Support H.R. 5171, the Legacy IRA Act, which would expand tax-free distributions from individual retirement accounts to include rollovers for charitable life-income plans for charitable purposes. Support H.R. 5196/S. 879, the AGE Act, which would allow caregivers a tax credit for up to $6,000 of the eldercare expenses incurred for their parentsor grandparents.

Client expense: $40,945 · Firm income: Not reported

Mortgage Interest Deduction HR6492 - Tax Benefit for Homeownership Clarification Act Small Business Tax Relief HR636 - America's Small Business Tax Relief Act of 2015 Tax Relief for Forgiven Mortgage Debt HR2029 - Consolidated Appropriations Act, 2016 Internet Sales Tax Fairness HR2775 - The Remote Transactions Parity Act of 2015 S698 - The Marketplace Fairness Act of 2015 HR5893 - No Regulation without Representation Act of 2016 Internet Tax Freedom HR235 - Permanent Internet Tax Freedom Act S431 - Internet Tax Freedom Forever Act Empowerment Zones Tax Incentives S408 - Empowering Jobs Act of 2015 Depreciation HR2510 - To amend the Internal Revenue Code of 1986 to modify and make permanent bonus depreciation. S1660 - A bill to amend the Internal Revenue Code of 1986 to modify and make permanent bonus depreciation. HR2029 - Consolidated Appropriations Act, 2016 Foreign Investment in Real Property Tax Act (FIRPTA) HR34 - Tax Increase Prevention and Real Estate Investment Act of 2015 HR2029 - Consolidated Appropriations Act, 2016 Carried Interest HR2889 - Carried Interest Fairness Act of 2015 S1686 - Carried Interest Fairness Act of 2015 Section 1031 Like-Kind Exchanges HR2844 - Keep Our Pension Promises Act S1631 - Keep Our Pension Promises Act First-time home buyer accounts HR5575 - First-Time Homebuyer Savings Account Act of 2016 S3175 - First-Time Homebuyer Credit Act of 2016 Definition of Derivatives S__ - Modernization of Derivatives Tax Act of 2016 (MODA) Homeowner Association Tax Deductions HR4696 - the HOME Act Low-Income Housing Tax Credits S2962 - Affordable Housing Credit Improvement Act of 2016 Discussions with the House Ways and Means Committee and Senate Finance Committee regarding tax reform priorities.

Client expense: $19,540,000 · 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 or otherwise disadvantaging multifamily real estate relative to other asset classes. 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 (while also increasing program resources) 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. We oppose proposals increasing taxes on capital gains. Finally, we favor: (1) repealing or reforming 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 Republican Tax Reform Blueprint, A Better Way: A Pro-Growth Tax Code for All Americans, all provisions. Energy H.R. 6376, to amend the Internal Revenue Code of 1986 to modify the energy efficient commercial buildings deduction, and for other purposes, all provisions. Supported extension of the Section 45L New Energy Efficient Home Credit, the Section 48 Energy Credit, and the Section 179D Energy Efficient Commercial Buildings Deduction (also favor improving the Commercial Buildings Deduction by establishing a sliding scale of energy improvements, which would help spur investment in energy efficient improvements in older buildings). Worker Classification H.R. 5008, Clarify Workers Misclassification in the Construction Industry Act, to direct the Secretary of the Treasury to improve tax compliance in the construction industry, including clarifying the employment status of service providers in the construction industry, and for other purposes, all provisions. Low-Income Housing Tax Credit (LIHTC) S. 2962, Affordable Housing Credit Improvement Act of 2016, to amend the Internal Revenue Code of 1986 to reform the low-income housing tax credit, and for other purposes, all provisions. S. 3237, Affordable Housing Credit Improvement Act of 2016, to amend the Internal Revenue Code of 1986 to reform the low-income housing tax credit, and for other purposes, all provisions. Workforce Housing S. 3384, Middle-Income Housing Tax Credit Act of 2016, to amend the Internal Revenue Code of 1986 to provide a credit for middle-income housing, all provisions. Carried Interest H.R. 2889/S.1686, Carried Interest Fairness Act of 2015, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-thru entities, all provisions. Partnership Audits P.L. 114-74, Bipartisan Budget Act of 2015, Section 1101, partnership audits and adjustments. H.R. 6439/S.3506, The Tax Technical Corrections Act of 2016, Section 101: Amendments Relating to Protecting Americans From Tax Hike Act of 2015, Exception from Qualified Pension Funds; Title II-Technical Corrections Related to Partnership Audit Rules, all provisions. Tax Regulations Department of the Treasury, Internal Revenue Service TD-9787, Section 707 Regarding Disguised Sales, Generally Department of the Treasury, Internal Revenue Service TD-9798, Liabilities Recognized as Recourse Partnership Liabilities Under Section 752 Department of the Treasury, Internal Revenue Service Proposed REG-122855-15, Liabilities Recognized as Recourse Partnership Liabilities Under Section 752 Department of the Treasury, Internal Revenue Service REG-163113-02, Estate, Gift, and Generation-Skipping Taxes; Restrictions on Liquidation of an Interest

S. 3384: Middle-Income Housing Tax Credit Act of 2016. This bill would create a new tax credit called the Middle-Income Housing Tax Credit (MIHTC) to work in conjunction with the Low-Income Housing Tax Credit (LIHTC). Under the bill, the federal government would allocate tax credits to the states based on population, starting with $1 per capita with a $1.14 million small state minimum. State housing authorities would then allocate the tax credits to developers through a competitive process; all provisions. S.2962: The Affordable Housing Credit Improvement Act of 2016. This bill seeks to expand the LIHTC by 50 percent and strengthen the program through other policy changes such as: creating incentives for projects that target homeless or extremely low income individuals and families, allowing a non-profit or government sponsor to acquire properties when the current 15 year compliance period expires, allow LIHTC properties to claim clean energy credits such as the Energy Efficient New Homes Credit, and aligning the LIHTC student rule more closely with the HUD student rule; all provisions. Government Accountability Office (GAO) Report Low-Income Housing Tax Credit: Some Agency Practices Raise Concerns and IRS Could Improve Noncompliance Reporting and Data Collection May, 2016 HUD Report "Understanding Whom the LIHTC Program Serves: Tenants in LIHTC Units as of December 31, 2012"; March 25, 2016 S.2962: "Affordable Housing Credit Improvement Act of 2016" May 19, 2016; all provisions. House Tax Reform Task Force tax reform blueprint titled A Pro-Growth Tax Code for All Americans. This tax reform blueprint promotes broad agenda items being pursued as part of House Speaker Paul Ryans (R-WI) A Better Way agenda to reform the tax system of the United States; provisions relating to the Low-Income Housing Tax Credit (LIHTC). Internal Revenue Service Final and Temporary Regulations: Utility Allowance Submetering March 3, 2016 - 26 CFR Part 1 [TD 9755] RIN 1545-BI91; all provisions relating to policies that amend the utility allowance regulations for the LIHTC. Internal Revenue Service Final and Temporary Regulations: Amendments to the Low-Income Housing Credit Compliance-Monitoring Regulations February 25, 2016 - 26 CFR Part 1 [TD 9753] RIN 1545-BL84; all provisions relating to the minimum number of units for which an agency must conduct physical inspections and low-income certifications. Office of Senator Maria Cantwell Addressing the Challenges of Affordable Housing and Homelessness: the Housing Tax Credit - a report detailing LIHTC usage and access for low-income families in the state of Washington and nationally. P.L. 114-113 (H.R. 2029): Consolidated Appropriations Act, 2016. Omnibus bill providing appropriations for the remainder of FY 2016; provisions under Division L, Transportation, Housing and Urban Development, and Related Agencies Appropriations Act, 2016: Title II - Department of Housing and Urban Development, Division A, Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2016: Title III - Rural Development Programs, and Division Q, Protecting Americans from Tax Hikes Act, 2016: Part IV - Incentives for Real Estate Investment, Section 131 Extension of minimum low-income housing tax credit rate for non-Federally subsidized buildings. Internal Revenue Service Memo [UIL 42.07.04]: Low-income Housing Credit (LIHC) - Noncompliance Resulting from Conflicting Program Requirements; all provisions HUD Memorandum, "Occupancy Protections for HUD-Assisted Households in Properties with Low-Income Housing Tax Credits" January 12, 2015; all provisions Department of Treasury Notice 2015-27, "Public Comment Invited on Recommendations for 2015-2016 Priority Guidance Plan" Submitted recommendations for tax reform in the United States to the Senate Finance Committee; provisions related to the low-income housing tax credit.

Proposals impacting the low-income housing credit, including H.R. 1142 and S. 1193; to make permanent and expand the temporary minimum credit rate for the low-income housing tax credit program. S.1946, Tax Relief Extension Act. H.R. 2029, Consolidated Appropriations Act. H.R. 3110/S. 1795, National Disaster Tax Relief Act. Proposals related to converting excess bonds into housing credits. S. 2962, Affordable Housing Credit Improvement Act. House Republican Tax Reform Task Force Blueprint. S. 3237, Affordable Housing Credit Improvement Act of 2016. S. 3384, the Middle-Income Housing Tax Credit Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Low-Income Housing Credit and associated affordable housing issues including legislation S. 3237 and S. 2962 the Affordable Housing Improvement Act

Client expense: Not reported · Firm income: $20,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

Issues surrounding the Low-Income Housing Tax Credit and affordable housing. S. 2962 and S. 3237 the Affordable Housing Improvement Act

Client expense: Not reported · Firm income: $20,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

Low-Income Housing Credit and associated affordable housing issues including legislation S. 3237 and S. 2962 the Affordable Housing Improvement Act

Client expense: Not reported · Firm income: $20,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

Issues surrounding the Low-Income Housing Tax Credit and affordable housing. S. 2962 and S. 3237 the Affordable Housing Improvement Act

Client expense: Not reported · Firm income: $20,000

Government targets: HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of

Tax Reform Promoted comprehensive approach to tax reform that avoids enacting reform for C corporations at the expense of flow-through entities or otherwise disadvantaging multifamily real estate relative to other asset classes. 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 (while also increasing program resources) 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. We oppose proposals increasing taxes on capital gains. Finally, we favor: (1) repealing or reforming 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 Republican Tax Reform Blueprint, A Better Way: A Pro-Growth Tax Code for All Americans, all provisions. Rep. Renacci, Simplifying America's Tax System Act of 2016, all provisions. Discussion Draft released by Senator Wyden, Cost Recovery Reform and Simplification Act of 1986, to amend the Internal Revenue Code of 1986 to modify rules relating to cost recovery, all provisions. Discussion Draft released by Senator Wyden, Modernization of Derivatives Tax Act of 2016, to amend the Internal Revenue Code of 1986 to modernize the tax treatment of derivatives and their underlying investments, and for other purposes, all provisions. Energy H.R. 5167, Technologies for Energy Security Act, to amend the Internal Revenue Code of 1986 to extend the credit for residential energy efficient property and the energy credit, Section 3: Extension of Energy Credit. Supported multi-year extension of Section 179D Energy Efficient Commercial Buildings Deduction (with the bipartisan refinements to the provision included in S. 1946, the Tax Relief Extension Act of 2015). Supported extension of the Section 45L New Energy Efficient Home Credit and the Section 48 Energy Credit. Low-Income Housing Tax Credit (LIHTC) S. 2962, Affordable Housing Credit Improvement Act of 2016, to amend the Internal Revenue Code of 1986 to reform the low-income housing tax credit, and for other purposes, all provisions. S. 3237, Affordable Housing Credit Improvement Act of 2016, to amend the Internal Revenue Code of 1986 to reform the low-income housing tax credit, and for other purposes, all provisions. Workforce Housing S. 3384, Middle-Income Housing Tax Credit Act of 2016, to amend the Internal Revenue Code of 1986 to provide a credit for middle-income housing, all provisions. Housing Affordability tax incentives (including developer tax incentives and bond preservation possibilities) S. 3175, First-Time Homebuyer Credit Act of 2016, to amend the Internal Revenue Code of 1986 to create a refundable first-time homebuyer tax credit, all provisions. Carried Interest H.R. 2889/S.1686, Carried Interest Fairness Act of 2015, to amend the Internal Revenue Code of 1986to provide for the proper tax treatment of personal service income earned in pass-thru entities, all provisions. Partnership Audits P.L. 114-74, Bipartisan Budget Act of 2015, Section 1101, partnership audits and adjustments. Tax Regulations Department of the Treasury, Internal Revenue Service REG-108060-15, Treatment of Certain Interests in Corporations as Stock or Indebtedness Department of the Treasury, Internal Revenue Service REG-163113-02, Estate, Gift, and Generation-Skipping Taxes; Restrictions on Liquidation of an Interest

S. 2962, Affordable Housing Credit Improvement Act of 2016, draft legislation on energy tax incentives

Client expense: $20,000 · Firm income: Not reported

Government targets: Army, Dept of (Other), Council on Environmental Quality (CEQ), Defense, Dept of (DOD), Energy, Dept of, Environmental Protection Agency (EPA), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), SENATE

H.R. 765, To amend the Internal Revenue Code of 1986 to permanently extend the 15-year recovery period for qualified leasehold improvement property, qualified restaurant property, and qualified retail improvement property. H.R. 855, To amend the Internal Revenue Code of 1986 to permanently extend the new markets tax credit, and for other purposes H.R. 1001, To amend the Internal Revenue Code of 1986 to terminate certain energy tax subsidies and lower the corporate income tax rate H.R. 1142, 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 H.R. 3110, National Disaster Tax Relief Act of 2015 S. 394, A bill to amend the Internal Revenue Code of 1986 to permanently extend the 15-year recovery period for qualified leasehold improvement property, qualified restaurant property, and qualified retail improvement property S. 591, New Markets Tax Credit Extension Act of 2015 S.1795, National Disaster Tax Relief Act of 2015 S. 2962, Affordable Housing Credit Improvement Act of 2016

Client expense: $137,712 · Firm income: Not reported

Government targets: HOUSE OF REPRESENTATIVES, SENATE

S. 2962, Affordable Housing Credit Improvement Act of 2016, draft legislation on energy tax incentives

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

Government targets: Army, Dept of (Other), Council on Environmental Quality (CEQ), Energy, Dept of, Environmental Protection Agency (EPA), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, SENATE

Small Business Tax Relief HR636 - America's Small Business Tax Relief Act of 2015 Tax Relief for Forgiven Mortgage Debt HR2029 - Consolidated Appropriations Act, 2016 Internet Sales Tax Fairness HR2775 - The Remote Transactions Parity Act of 2015 S698 - The Marketplace Fairness Act of 2015 HR5893 - No Regulation without Representation Act of 2016 Internet Tax Freedom HR235 - Permanent Internet Tax Freedom Act S431 - Internet Tax Freedom Forever Act Empowerment Zones Tax Incentives S408 - Empowering Jobs Act of 2015 Depreciation HR2510 - To amend the Internal Revenue Code of 1986 to modify and make permanent bonus depreciation. S1660 - A bill to amend the Internal Revenue Code of 1986 to modify and make permanent bonus depreciation. HR2029 - Consolidated Appropriations Act, 2016 Foreign Investment in Real Property Tax Act (FIRPTA) HR34 - Tax Increase Prevention and Real Estate Investment Act of 2015 HR2029 - Consolidated Appropriations Act, 2016 Carried Interest HR2889 - Carried Interest Fairness Act of 2015 S1686 - Carried Interest Fairness Act of 2015 Section 1031 Like-Kind Exchanges HR2844 - Keep Our Pension Promises Act S1631 - Keep Our Pension Promises Act First-time home buyer accounts HR5575 - First-Time Homebuyer Savings Account Act of 2016 S3175 - First-Time Homebuyer Credit Act of 2016 Definition of Derivatives S__ - Modernization of Derivatives Tax Act of 2016 (MODA) Homeowner Association Tax Deductions HR4696 - the HOME Act Low-Income Housing Tax Credits S2962 - Affordable Housing Credit Improvement Act of 2016 Discussions with the House Ways and Means Committee and the Senate Finance Committee regarding extending the Section 179-D Energy Efficient Commercial Buildings deduction.

Client expense: $23,800,000 · Firm income: Not reported

25C, 45L, Low Income Housing Tax Credit, carried interest, tax reform, mortgage interest deduction, 25D, 179D, Legislation to improve and to make the Low Income Housing Tax Credit permanent, Tax Extenders Legislation, S. 3384: Middle-Income Housing Tax Credit Act of 2016, S. 2962: Affordable Housing Credit Improvement Act of 2016, S. 3237: Affordable Housing Credit Improvement Act of 2016.

Client expense: $720,000 · Firm income: Not reported

Proposals impacting the low-income housing credit, including H.R. 1142 and S. 1193; to make permanent and expand the temporary minimum credit rate for the low-income housing tax credit program. S.1946, Tax Relief Extension Act. H.R. 2029, Consolidated Appropriations Act. H.R. 3110/S. 1795, National Disaster Tax Relief Act. Proposals related to converting excess bonds into housing credits. S. 2962, Affordable Housing Credit Improvement Act. House Republican Tax Reform Task Force Blueprint. S. 3237, Affordable Housing Credit Improvement Act of 2016. S. 3384, the Middle-Income Housing Tax Credit Act.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Support continued tax-exempt status for charitable organizations and tax incentives for charitable giving. Support S. 2962, the Affordable Housing Credit Improvement Act, to increase states' Low Income Housing Tax Credit allocations by 50% over a five-year period, allow for income averaging in the LIHTC program, and make the 4% tax credit rate floor permanent for acquisition and bond-financed projects. Support S. 2750, the CHARITY Act, which would allow more flexibility for tax-free rollovers of IRA funds to charitable organizations. Support H.R. 5171, the Legacy IRA Act, which would expand tax-free distributions from individual retirement accounts to include rollovers for charitable life-income plans for charitable purposes. Support H.R. 5196/S. 879, the AGE Act, which would allow caregivers a tax credit for up to $6,000 of the eldercare expenses incurred for their parentsor grandparents.

Client expense: $40,945 · Firm income: Not reported

S. 3384: Middle-Income Housing Tax Credit Act of 2016. This bill would create a new tax credit called the Middle-Income Housing Tax Credit (MIHTC) to work in conjunction with the Low-Income Housing Tax Credit (LIHTC). Under the bill, the federal government would allocate tax credits to the states based on population, starting with $1 per capita with a $1.14 million small state minimum. State housing authorities would then allocate the tax credits to developers through a competitive process; all provisions. S.2962: The Affordable Housing Credit Improvement Act of 2016. This bill seeks to expand the LIHTC by 50 percent and strengthen the program through other policy changes such as: creating incentives for projects that target homeless or extremely low income individuals and families, allowing a non-profit or government sponsor to acquire properties when the current 15 year compliance period expires, allow LIHTC properties to claim clean energy credits such as the Energy Efficient New Homes Credit, and aligning the LIHTC student rule more closely with the HUD student rule; all provisions. Government Accountability Office (GAO) Report Low-Income Housing Tax Credit: Some Agency Practices Raise Concerns and IRS Could Improve Noncompliance Reporting and Data Collection May, 2016 HUD Report "Understanding Whom the LIHTC Program Serves: Tenants in LIHTC Units as of December 31, 2012"; March 25, 2016 S.2962: "Affordable Housing Credit Improvement Act of 2016" May 19, 2016; all provisions. House Tax Reform Task Force tax reform blueprint titled A Pro-Growth Tax Code for All Americans. This tax reform blueprint promotes broad agenda items being pursued as part of House Speaker Paul Ryans (R-WI) A Better Way agenda to reform the tax system of the United States; provisions relating to the Low-Income Housing Tax Credit (LIHTC). Internal Revenue Service Final and Temporary Regulations: Utility Allowance Submetering March 3, 2016 - 26 CFR Part 1 [TD 9755] RIN 1545-BI91; all provisions relating to policies that amend the utility allowance regulations for the LIHTC. Internal Revenue Service Final and Temporary Regulations: Amendments to the Low-Income Housing Credit Compliance-Monitoring Regulations February 25, 2016 - 26 CFR Part 1 [TD 9753] RIN 1545-BL84; all provisions relating to the minimum number of units for which an agency must conduct physical inspections and low-income certifications. Office of Senator Maria Cantwell Addressing the Challenges of Affordable Housing and Homelessness: the Housing Tax Credit - a report detailing LIHTC usage and access for low-income families in the state of Washington and nationally. P.L. 114-113 (H.R. 2029): Consolidated Appropriations Act, 2016. Omnibus bill providing appropriations for the remainder of FY 2016; provisions under Division L, Transportation, Housing and Urban Development, and Related Agencies Appropriations Act, 2016: Title II - Department of Housing and Urban Development, Division A, Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2016: Title III - Rural Development Programs, and Division Q, Protecting Americans from Tax Hikes Act, 2016: Part IV - Incentives for Real Estate Investment, Section 131 Extension of minimum low-income housing tax credit rate for non-Federally subsidized buildings. Internal Revenue Service Memo [UIL 42.07.04]: Low-income Housing Credit (LIHC) - Noncompliance Resulting from Conflicting Program Requirements; all provisions HUD Memorandum, "Occupancy Protections for HUD-Assisted Households in Properties with Low-Income Housing Tax Credits" January 12, 2015; all provisions Department of Treasury Notice 2015-27, "Public Comment Invited on Recommendations for 2015-2016 Priority Guidance Plan" Submitted recommendations for tax reform in the United States to the Senate Finance Committee; provisions related to the low-income housing tax credit.

S. 2962, Affordable Housing Credit Improvement Act of 2016, draft legislation on energy tax incentives

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

Government targets: Army, Dept of (Other), Council on Environmental Quality (CEQ), Energy, Dept of, Environmental Protection Agency (EPA), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), SENATE

S. 2962, Affordable Housing Credit Improvement Act of 2016, draft legislation on energy tax incentives

Client expense: $20,000 · Firm income: Not reported

Government targets: Army, Dept of (Other), Council on Environmental Quality (CEQ), Defense, Dept of (DOD), Energy, Dept of, Environmental Protection Agency (EPA), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Housing & Urban Development, Dept of (HUD), SENATE

Tax Reform Promoted comprehensive approach to tax reform that avoids enacting reform for C corporations at the expense of flow-through entities or otherwise disadvantaging multifamily real estate relative to other asset classes. 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 (while also increasing program resources) 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. We oppose proposals increasing taxes on capital gains. Finally, we favor: (1) repealing or reforming 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 Republican Tax Reform Blueprint, A Better Way: A Pro-Growth Tax Code for All Americans H.R. 4377, American Business Competitiveness Act of 2015, to amend the Internal Revenue Code of 1986 to tax business income on a cash flow basis and for other purposes, all provisions. Draft legislation, Simplifying America's Tax System Act of 2016, all provisions. Discussion Draft released by Senator Wyden, Cost Recovery Reform and Simplification Act of 1986, to amend the Internal Revenue Code of 1986 to modify rules relating to cost recovery, all provisions. Discussion Draft released by Senator Wyden, Modernization of Derivatives Tax Act of 2016, to amend the Internal Revenue Code of 1986 to modernize the tax treatment of derivatives and their underlying investments, and for other purposes, all provisions. Senate Committee on Finance Chairman's Staff Discussion Draft to Reform Certain Business Provisions (113th Congress). 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. Tax reform proposals for which legislation has yet been introduced to provide for corporate integration. Energy H.R. 5167, Technologies for Energy Security Act, to amend the Internal Revenue Code of 1986 to extend the credit for residential energy efficient property and the energy credit, all provisions. Supported multi-year extension of Section 179D Energy Efficient Commercial Buildings Deduction (with the bipartisan refinements to the provision included in S. 1946, the Tax Relief Extension Act of 2015). We also supported extension of the Section 45L New Energy Efficient Home Credit and the Section 48 Energy Credit. Low-Income Housing Tax Credit (LIHTC) S. 2962, Affordable Housing Credit Improvement Act of 2016, to amend the Internal Revenue Code of 1986 to reform the low-income housing tax credit, and for other purposes, all provisions. Draft legislation to amend the Internal Revenue Code of 1986 to allow the conversion of private activity bond volume cap into State housing credit ceiling for allocation under the low-income housing tax credit, all provisions. Obama Administration FY 2017 Revenue Proposal, Reform and Expand the Low-Income Housing Tax Credit, Allow Conversion of Private Activity Bond Volume Cap into LIHTCs and Encourage Mixed Income Occupancy by allowing LIHTC-Supported Projects to Elect a Criterion Employing a Restriction on Average Income. Carried Interest H.R. 2889, Carried Interest Fairness Act of 2015, to amend the Internal Revenue Code of 1986to provide for the proper tax treatment of personal service income earned in pass-thru entities, all provisions. S. 1686, Carried Interest Fairness Act of 2015, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-thru entities, all provisions. Obama Administration FY 2017 Revenue Proposal, Tax Carried (Profits) Interests as Ordinary Income Partnership Audits P.L. 114-74, H.R. 1314, Bipartisan Budget Act of 2015, Section 1101, partnership audits and adjustments. IRS Notice 2016-23, Request for Comments Regarding Implementation of the New Partnership Audit Regime Enacted as Part of the Bipartisan Budget Act of 2015 Housing Affordability Housing Affordability tax incentives (including developer tax incentives and bond preservation possibilities) H.R. 5082 / S. 2868, Investing in Opportunity Act, to amend the Internal Revenue Code of 1986 to provide for the deferral of inclusion in gross income for capital gains reinvested in economically distressed zones, all provisions. H.R. 5539, Preserving Investment in Needy Neighborhoods Act, to amend the Internal Revenue Code of 1986 to exclude from gross income contributions to the capital of a partnership, all provisions. Worker Classification H.R. 5008, Clarify Workers Misclassification in the Construction Industry Act, to direct the Secretary of the Treasury to improve tax compliance in the construction industry, including clarifying the employment status of service providers in the construction industry, and for other purposes, all provisions. Tax Regulations Internal Revenue Service REG-129067-15, Definition of Political Subdivision Department of the Treasury, Internal Revenue Service REG-108060-15, Treatment of Certain Interests in Corporations as Stock or Indebtedness

Support continued tax-exempt status for charitable organizations and tax incentives for charitable giving. Support S. 2962, the Affordable Housing Credit Improvement Act, to increase states' Low Income Housing Tax Credit allocations by 50% over a five-year period, allow for income averaging in the LIHTC program, and make the 4% tax credit rate floor permanent for acquisition and bond-financed projects. Support S. 2750, the CHARITY Act, which would allow more flexibility for tax-free rollovers of IRA funds to charitable organizations. Support H.R. 5171, the Legacy IRA Act, which would expand tax-free distributions from individual retirement accounts to include rollovers for charitable life-income plans for charitable purposes. Support H.R. 5196/S. 879, the AGE Act, which would allow caregivers a tax credit for up to $6,000 of the eldercare expenses incurred for their parentsor grandparents.

Client expense: $57,010 · Firm income: Not reported

Proposals impacting the low-income housing credit, including H.R. 1142 and S. 1193; to make permanent and expand the temporary minimum credit rate for the low-income housing tax credit program. S.1946, Tax Relief Extension Act. H.R. 2029, Consolidated Appropriations Act. H.R. 3110/S. 1795, National Disaster Tax Relief Act. Proposals related to converting excess bonds into housing credits. S. 2962, Affordable Housing Credit Improvement Act. House Republican Tax Reform Task Force Blueprint.

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

Government targets: HOUSE OF REPRESENTATIVES, SENATE

Government Accountability Office (GAO) Report Low-Income Housing Tax Credit: Some Agency Practices Raise Concerns and IRS Could Improve Noncompliance Reporting and Data Collection May, 2016 HUD Report "Understanding Whom the LIHTC Program Serves: Tenants in LIHTC Units as of December 31, 2012"; March 25, 2016 S.2962: "Affordable Housing Credit Improvement Act of 2016" May 19, 2016; all provisions. House Tax Reform Task Force tax reform blueprint titled A Pro-Growth Tax Code for All Americans. This tax reform blueprint promotes broad agenda items being pursued as part of House Speaker Paul Ryans (R-WI) A Better Way agenda to reform the tax system of the United States; provisions relating to the Low-Income Housing Tax Credit (LIHTC). Internal Revenue Service Final and Temporary Regulations: Utility Allowance Submetering March 3, 2016 - 26 CFR Part 1 [TD 9755] RIN 1545-BI91; all provisions relating to policies that amend the utility allowance regulations for the LIHTC. Internal Revenue Service Final and Temporary Regulations: Amendments to the Low-Income Housing Credit Compliance-Monitoring Regulations February 25, 2016 - 26 CFR Part 1 [TD 9753] RIN 1545-BL84; all provisions relating to the minimum number of units for which an agency must conduct physical inspections and low-income certifications. Office of Senator Maria Cantwell Addressing the Challenges of Affordable Housing and Homelessness: the Housing Tax Credit - a report detailing LIHTC usage and access for low-income families in the state of Washington and nationally. P.L. 114-113 (H.R. 2029): Consolidated Appropriations Act, 2016. Omnibus bill providing appropriations for the remainder of FY 2016; provisions under Division L, Transportation, Housing and Urban Development, and Related Agencies Appropriations Act, 2016: Title II - Department of Housing and Urban Development, Division A, Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Appropriations Act, 2016: Title III - Rural Development Programs, and Division Q, Protecting Americans from Tax Hikes Act, 2016: Part IV - Incentives for Real Estate Investment, Section 131 Extension of minimum low-income housing tax credit rate for non-Federally subsidized buildings. Internal Revenue Service Memo [UIL 42.07.04]: Low-income Housing Credit (LIHC) - Noncompliance Resulting from Conflicting Program Requirements; all provisions HUD Memorandum, "Occupancy Protections for HUD-Assisted Households in Properties with Low-Income Housing Tax Credits" January 12, 2015; all provisions Department of Treasury Notice 2015-27, "Public Comment Invited on Recommendations for 2015-2016 Priority Guidance Plan" Submitted recommendations for tax reform in the United States to the Senate Finance Committee; provisions related to the low-income housing tax credit.