Middle-Income Housing Tax Credit Act of 2018

Reconciliation Legislation Senate Finance Committee, Draft Text of Build Back Better Act, Title XII -- Committee on Finance, Subtitle E -- Infrastructure Financing and Community Development, Part 1 -- Low-Income Housing Credit, Section 125101: Increases in State Allocations, Section 125102: Tax-Exempt Bond Financing Requirement; and Section 125103: Buildings Designated to Serve Extremely Low-Income Households; Subtitle F -- Green Energy, Part 3 -- Green Energy and Efficiency Incentives for Individuals, Section 126303: Energy Efficient Commercial Buildings Deduction and Section 126304: Extension, Increase, and Modifications of New Energy Efficient Home Credit; Subtitle H -- Responsibly Funding Our Priorities, Part 1 -- Corporate and International Tax Reforms, Subpart A -- Corporate Tax Rate, Section 128101: Corporate Alternative Minimum Tax; Part 2: Tax Increases for High-Income Individuals, Section 128201: Application of Net Investment Income Tax to Trade or Business Income of Certain High Income Individuals, Section 128202: Limitations on Excess Business Losses of Noncorporate Taxpayers, and Section 128203: Surcharge on High Income Individuals, Estates, and Trusts. H.R. 5376 (as amended by House Rules Committee Print 117-18, the version of the bill that passed the House of Representatives November 19, 2021), Build Back Better Act, Title XIII -- Committee on Ways and Means, Subtitle E -- Infrastructure Financing and Community Development, Part 1 -- Low Income Housing Credit, Section 135101: Increase in State Allocations, Section 135102: Tax-Exempt Bond Financing Requirement, and Section 135103 Buildings Designated to Serve Extremely Low-Income Households; Subtitle F -- Green Energy, Part 3 -- Green Energy and Efficiency Incentives for Individuals, Section 136303: Energy Efficient Commercial Buildings Deduction and Section 136304: Extension, Increase, and Modifications of New Energy Efficient Home Credit. Subtitle H -- Responsibly Funding Our Priorities, Part 1 -- Corporate and International Tax Reforms, Subpart A -- Corporate Tax Rate, Section 138101: Corporate Alternative Minimum Tax; Part 2: Tax Increases for High-Income Individuals, Section 138201: Application of Net Investment Income Tax to Trade or Business Income of Certain High Income Individuals, Section 138202: Limitations on Excess Business Losses of Noncorporate Taxpayers, and Section 138203: Surcharge on High Income Individuals, Estates, and Trusts. House Rules Committee Print 117-17, Text of H.R. 5376, Build Back Better Act, Title XIII -- Committee on Ways and Means, Subtitle D -- Green Energy, Part 3 -- Green Energy and Efficiency Incentives for Individuals, Section 136303: Energy Efficient Commercial Buildings Deduction and Section 136304: Extension, Increase, and Modifications of New Energy Efficient Home Credit. Subtitle G -- Responsibly Funding Our Priorities, Part 1 -- Corporate and International Tax Reforms, Subpart A -- Corporate Tax Rate, Section 138101: Corporate Alternative Minimum Tax; Part 2: Tax Increases for High-Income Individuals, Section 138201: Application of Net Investment Income Tax to Trade or Business Income of Certain High Income Individuals, Section 138202: Limitations on Excess Business Losses of Noncorporate Taxpayers, and Section 138203: Surcharge on High Income Individuals, Estates, and Trusts. H.R. 5376, to provide for reconciliation pursuant to title II of S. Con. Res. 14, TITLE IV-COMMITTEE ON FINANCIAL SERVICES, Subtitle A-Creating and Preserving Affordable, Equitable and Accessible Housing for the 21st Century, Title XIII -- Committee on Ways and Means, Subtitle F -- Infrastructure Financing and Community Development, Part 3 -- Rehabilitation Tax Credit, Section 135301: Determination of Credit Percentage, Section 135302: Increase in the Rehabilitation Credit for Certain Small Projects, Section 135303: Modification of Definition of Substantially Rehabilitated, and Section 135304: Elimination of Rehabilitation Credit Basis Adjustment; Part 5 -- Housing, Subpart A -- Low-Income Housing Tax Credit, Section 135501: Increase in State Allocations, Section 135502: Tax-Exempt Bond Financing Requirement, Section 135503: Buildings Designated to Serve Extremely Low-Income Households, Section 135504: Inclusion of Rural Areas as Difficult Development Areas, and Section 135507: Increase in Credit for Bond-Financed Projects Designated by Housing Credit Agency; Subtitle G -- Green Energy, Part 3 -- Green Energy and Efficiency Incentives for Individuals, Section 136303: Energy Efficient Commercial Buildings Deduction and Section 136304: Extension, Increase, and Modifications of New Energy Efficient Home Credit. Subtitle I -- Responsibly Funding Our Priorities, Part 1 -- Corporate and International Tax Reforms, Subpart E -- Other Business Tax Provisions, Section 138149: Modification of Rules for Partnership Interests Held in Connection with the Performance of Services; Part 2: Tax Increases for High-Income Individuals, Section 138201: Increase in Top Marginal Individual Income Tax Rate, Section 138202: Increase in Capital Gains Rate for Certain High Income Individuals, Section 138203: Application of Net Investment Income Tax to Trade or Business Income of Certain High Income Individuals, Section 138204: Limitation on Deduction of Qualified Business Income for Certain High Income Individuals, Section 138205: Limitations on Excess Business Losses of Noncorporate Taxpayers, Section 138206: Surcharge on High Income Individuals, Estates, and Trusts, and Section 138207: Termination of Temporary Increase in Unified Credit; Part 3 -- Modifications of Rules Relating to Retirement Plans, Subpart B -- Other Provisions Relating to Individual Retirement Accounts, Section 138312: Prohibitions of IRA Investments Conditioned on Account Holder Status Taxation of Pass-Through Entities Senator Wyden Pass-Through Reform Discussion Draft, all provisions. Corporate Minimum Tax S. 2680, Real Corporate Profits Tax Act of 2021, to amend the Internal Revenue Code of 1986 to impose a tax on real profits of certain corporations, all provisions. Draft legislation, Senators, Elizabeth Warren, Angus King, and Ron Wyden, Corporate Profits Minimum Tax Proposal, all provisions. H.R. 4940, Real Corporate Profits Tax Act of 2021, to amend the Internal Revenue Code of 1986 to impose a tax on real profits of certain corporations, all provisions. Low-Income Housing Tax Credit and Middle-Income Housing Tax Credit Requested inclusion of provisions benefiting the Low-Income Housing Tax Credit as part of Build Back Better legislation. Support making permanent and augmenting by an additional 50 percent the increased Low-Income Housing Tax Credit credit authority enacted in March 2018 to enable the production of new units. S. 2820, Decent, Affordable, Safe Housing for All Act (DASH Act), to provide rental housing vouchers for the homeless, and for other purposes, Title I -- Housing Assistance, Subtitle A -- General Housing Assistance, Section 111: Rental Vouchers for the Homeless, portion of section pertaining to source of income rules; Title II -- Revenue Provisions: Sections 201-214 pertaining to the Low-Income Housing Tax Credit, Section 215 establishing a renter's tax credit, and Section 216 establishing a middle-income housing tax credit. S. 3365 (115th Congress), Middle-Income Housing Tax Credit Act of 2018, to amend the Internal Revenue Code of 1986 to provide a credit for middle-income housing, and for other purposes, all provisions. Department of the Treasury, Internal Revenue Service, 26 CFR Part 1, REG-119890-18, RIN 1454 BO92, Section 42, Low-Income Housing Credit Average Income Test Regulations. Requested Treasury and IRS either finalize the proposed rule with modifications (impacting minimum set asides, unit designations, casualty losses, mitigating actions, and existing developments) or announce its intention to publish a new rule. Requested that Treasury modify its guidance to allow states and local governments to maximize the efficacy of Fiscal Recovery Funds used with the Low-Income Housing Tax Credit by recommending that Treasury publish guidance to: (1) clarify that Fiscal Recovery Funds structured as grants do not result in an eligible basis reduction in Housing Credit developments regardless of sponsor type, consistent with treatment of Tax Credit Exchange funds administered by the Treasury during the 2009 economic recovery; and (2) provide authority to use Fiscal Recovery Funds for principal amounts on loans with maturities beyond 2026-not just for the "cost of the loan" as currently outlined in the Interim Rule-and to allow repayments of funds to be used for similar affordable housing purposes, even after the 2026 deadline. Signed letter to Treasury. Energy Tax Incentives Support long-term extension of New energy efficient home credit (IRC 45L). Support expansion of Energy efficient commercial buildings deduction (IRC 179D) to establish a sliding scale of energy improvements, which would help spur investment in energy efficient improvements in older buildings. Biden Tax Proposals President Biden, Build Back Better Framework (released October 28, 2021), tax provisions imposing 15 percent corporate minimum tax on large corporations, establishing tax rate surcharges, applying the net investment income tax to a broader share of earnings, and limiting pass-through business losses. Like-kind exchanges: Support retaining current law. Capital Gains - Oppose doubling the long-term capital gains tax rate and support significant differential between ordinary income and capital gains tax rates. Carried interest: NMHC believes that carried interest should be treated as a long-term capital gain if the underlying asset is held for at least one year. Stepped-Up Basis at Death and Taxation of Unrealized Capital Gains at Death: Support retaining current law providing for stepped-up basis at death and taxation of capital gains upon actual sale. Estate Tax: Support making permanent the Estate Tax rules enacted as part of the Tax Cuts and Jobs Act of 2017. Opportunity Zones Requested Congress extend the recognition date for deferred capital gains invested into Opportunity Funds by two years, through the end of 2028. Also support enhanced information reporting, data collection, and transparency with regard to Opportunity Zones. Finally, support reducing the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes. Fire Sprinklers H.R. 6192, High Rise Fire Sprinkler Incentive Act of 2021, to amend the Internal Revenue Code of 1986 to classify certain automatic fire sprinkler system retrofits as 15-year property for purposes of depreciation, all provisions.

Client expense: $1,650,000 · Firm income: Not reported

Government targets: Consumer Financial Protection Bureau (CFPB), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Deposit Insurance Corporation (FDIC), Federal Emergency Management Agency (FEMA), Federal Housing Finance Agency (FHFA), Federal Reserve System, Government Accountability Office (GAO), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Internal Revenue Service (IRS), Justice, Dept of (DOJ), Office of the Comptroller of the Currency (OCC), SENATE, Small Business Administration (SBA), Transportation, Dept of (DOT), Treasury, Dept of, U.S. Postal Service (USPS)

GSE Reform Bills LIHTC Improvements: Affordable Housing Credit Improvement Act (S. 1703 H.R. 3077); Middle Income Housing Tax Credit Act (S. 3365) Section 8 housing choice voucher reform Yes in My Backyard Act (S. 1919 H.R. 451) Manufactured Housing Modernization Act (S. 1804) GSA disposition of federal properties for housing purposes Housing is Infrastructure Act (H.R. 5187) Build more Housing Near Transit Act (H.R. 4307) Federal Reserve Credit Facilities CDC eviction ban, mortgage forbearance matters

Client expense: $1,008,590 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Director of National Intelligence (ODNI), Energy, Dept of, Environmental Protection Agency (EPA), Federal Accounting Standards Advisory Board (FASAB), Federal Bureau of Investigation (FBI), Federal Deposit Insurance Corporation (FDIC), Federal Energy Regulatory Commission (FERC), 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), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, White House Office

GSE Reform Bills LIHTC Improvements: Affordable Housing Credit Improvement Act (S. 1703 H.R. 3077); Middle Income Housing Tax Credit Act (S. 3365) Section 8 housing choice voucher reform Yes in My Backyard Act (S. 1919 H.R. 451) Manufactured Housing Modernization Act (S. 1804) GSA disposition of federal properties for housing purposes Housing is Infrastructure Act (H.R. 5187) Build more Housing Near Transit Act (H.R. 4307) Federal Reserve Credit Facilities CDC eviction ban, mortgage forbearance matters

Client expense: $1,543,764 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Director of National Intelligence (ODNI), Energy, Dept of, Environmental Protection Agency (EPA), Federal Accounting Standards Advisory Board (FASAB), Federal Bureau of Investigation (FBI), Federal Deposit Insurance Corporation (FDIC), Federal Energy Regulatory Commission (FERC), 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), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, White House Office

Reconciliation Legislation H.R. 5376, to provide for reconciliation pursuant to title II of S. Con. Res. 14, Title XIII -- Committee on Ways and Means, Subtitle F -- Infrastructure Financing and Community Development, Part 3 -- Rehabilitation Tax Credit, Section 135301: Determination of Credit Percentage, Section 135302: Increase in the Rehabilitation Credit for Certain Small Projects, Section 135303: Modification of Definition of Substantially Rehabilitated, and Section 135304: Elimination of Rehabilitation Credit Basis Adjustment; Part 5 -- Housing, Subpart A -- Low-Income Housing Tax Credit, Section 135501: Increase in State Allocations, Section 135502: Tax-Exempt Bond Financing Requirement, Section 135503: Buildings Designated to Serve Extremely Low-Income Households, Section 135504: Inclusion of Rural Areas as Difficult Development Areas, and Section 135507: Increase in Credit for Bond-Financed Projects Designated by Housing Credit Agency; Subtitle G -- Green Energy, Part 3 -- Green Energy and Efficiency Incentives for Individuals, Section 136303: Energy Efficient Commercial Buildings Deduction and Section 136304: Extension, Increase, and Modifications of New Energy Efficient Home Credit. Subtitle I -- Responsibly Funding Our Priorities, Part 1 -- Corporate and International Tax Reforms, Subpart E -- Other Business Tax Provisions, Section 138149: Modification of Rules for Partnership Interests Held in Connection with the Performance of Services; Part 2: Tax Increases for High-Income Individuals, Section 138201: Increase in Top Marginal Individual Income Tax Rate, Section 138202: Increase in Capital Gains Rate for Certain High Income Individuals, Section 138203: Application of Net Investment Income Tax to Trade or Business Income of Certain High Income Individuals, Section 138204: Limitation on Deduction of Qualified Business Income for Certain High Income Individuals, Section 138205: Limitations on Excess Business Losses of Noncorporate Taxpayers, Section 138206: Surcharge on High Income Individuals, Estates, and Trusts, and Section 138207: Termination of Temporary Increase in Unified Credit; Part 3 -- Modifications of Rules Relating to Retirement Plans, Subpart B -- Other Provisions Relating to Individual Retirement Accounts, Section 138312: Prohibitions of IRA Investments Conditioned on Account Holder Status House Committee on Ways and Means, Amendment in the Nature of a Substitute to the Revenue Provisions of Subtitles F, G, H, I, and J of the Budget Reconciliation Legislative Recommendations Relating to Infrastructure Financing and Community Development, Green Energy, Social Safety Net, Responsibly Financing Our Priorities, and Prescription Drug Pricing: Subtitle F -- Infrastructure Financing and Community Development, Part 3 -- Rehabilitation Tax Credit, Section 135301: Determination of Credit Percentage, Section 135302: Increase in the Rehabilitation Credit for Certain Small Projects, Section 135303: Modification of Definition of Substantially Rehabilitated, and Section 135304: Elimination of Rehabilitation Credit Basis Adjustment; Part 5 -- Housing, Subpart A -- Low-Income Housing Tax Credit, Section 135501: Increase in State Allocations, Section 135502: Tax-Exempt Bond Financing Requirement, Section 135503: Buildings Designated to Serve Extremely Low-Income Households, Section 135504: Inclusion of Rural Areas as Difficult Development Areas, and Section 135507: Increase in Credit for Bond-Financed Projects Designated by Housing Credit Agency; Subtitle G -- Green Energy, Part 3 -- Green Energy and Efficiency Incentives for Individuals, Section 136303: Energy Efficient Commercial Buildings Deduction and Section 136304: Extension, Increase, and Modifications of New Energy Efficient Home Credit. Subtitle I -- Responsibly Funding Our Priorities, Part 1 -- Corporate and International Tax Reforms, Subpart E -- Other Business Tax Provisions, Section 138149: Modification of Rules for Partnership Interests Held in Connection with the Performance of Services; Part 2: Tax Increases for High-Income Individuals, Section 138201: Increase in Top Marginal Individual Income Tax Rate, Section 138202: Increase in Capital Gains Rate for Certain High Income Individuals, Section 138203: Application of Net Investment Income Tax to Trade or Business Income of Certain High Income Individuals, Section 138204: Limitation on Deduction of Qualified Business Income for Certain High Income Individuals, Section 138205: Limitations on Excess Business Losses of Noncorporate Taxpayers, Section 138206: Surcharge on High Income Individuals, Estates, and Trusts, and Section 138207: Termination of Temporary Increase in Unified Credit; Part 3 -- Modifications of Rules Relating to Retirement Plans, Subpart B -- Other Provisions Relating to Individual Retirement Accounts, Section 138312: Prohibitions of IRA Investments Conditioned on Account Holder Status Taxation of Pass-Through Entities Section 199A Qualified Business Income Tax Deduction: Oppose any reduction to or repeal of the 20-percent deduction for qualified business income under Section 199A, including phasing out the deduction above certain income thresholds. S. 2387, Small Business Tax Fairness Act, to amend the Internal Revenue Code of 1986 to improve the deduction for qualified business income, all provisions. Senator Wyden Pass-Through Reform Discussion Draft, all provisions. Low-Income Housing Tax Credit and Middle-Income Housing Tax Credit H.R. 2573, Affordable Housing Credit Improvement Act of 2021, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 1136, Affordable Housing Credit Improvement Act of 2021, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 2820, Decent, Affordable, Safe Housing for All Act (DASH Act), to provide rental housing vouchers for the homeless, and for other purposes, Title I -- Housing Assistance, Subtitle A -- General Housing Assistance, Section 111: Rental Vouchers for the Homeless, portion of section pertaining to source of income rules; Title II -- Revenue Provisions: Sections 201-214 pertaining to the Low-Income Housing Tax Credit, Section 215 establishing a renter's tax credit, and Section 216 establishing a middle-income housing tax credit. S. 3365 (115th Congress), Middle-Income Housing Tax Credit Act of 2018, to amend the Internal Revenue Code of 1986 to provide a credit for middle-income housing, and for other purposes, all provisions. Analyzed legislative proposal to establish a 6 percent Low-Income Housing Tax Credit Rehabilitation Tax Credit H.R. 1483, Revitalizing Economies, Housing, and Businesses Act of 2021 or the REHAB Act of 2021, to amend the Internal Revenue Code of 1986 to modify the rehabilitation credit, all provisions. Energy Tax Incentives H.R. 848, Growing Renewable Energy and Efficiency Now Act of 2021 (GREEN Act of 2021), to amend the Internal Revenue Code of 1986 to provide incentives for renewable energy and energy efficiency, and for other purposes, Section 303: Energy Efficient Commercial Buildings Deduction and Section 304: Extension, Increase, and Modifications of New Energy Efficient Home Credit. S. 2118, Clean Energy for America Act, to amend the Internal Revenue Code of 1986 to provide tax incentives for increased investment in clean energy: Title III -- Incentives for Energy Efficiency, Section 301: Credit for new energy efficient residential buildings and Section 303: Enhancement of energy efficient commercial buildings deduction; and Title V -- Workforce Development Requirements, Section 501: Use of qualified apprentices. H.R. 5188 New Home Energy Efficient Act of 2021 Support long-term extension of New energy efficient home credit (IRC 45L). Support expansion of Energy efficient commercial buildings deduction (IRC 179D) to establish a sliding scale of energy improvements, which would help spur investment in energy efficient improvements in older buildings. Biden Tax Proposals Department of the Treasury, General Explanations of the Administration's Fiscal Year 2022 Revenue Proposals, American Families Plan: Increase the Top Marginal Income Tax Rate for High Earners, Reform the Taxation of Capital Income, Rationalize Net Investment Income and Self-Employment Contribution Act Taxes, Tax Carried (Profits) Interests as Ordinary Income, and Repeal Deferral of Gain from Like-Kind Exchanges. Like-kind exchanges: Support retaining current law. S. Amdt. 3753 (to establish a deficit-neutral reserve fund relating to maintaining the current law tax treatment of like kind exchanges) to S. Con Res. 14 (a concurrent resolution setting forth the congressional budget for the United States Government for fiscal year 2022 and setting forth the appropriate budgetary levels for fiscal years 2023 through 2031). Capital Gains - Oppose doubling the long-term capital gains tax rate. Carried interest: NMHC believes that carried interest should be treated as a long-term capital gain if the underlying asset is held for at least one year. H.R. 1068, Carried Interest Fairness Act of 2021, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-thru entities, all provisions. S. 1598, Carried Interest Fairness Act of 2021, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-thru entities, all provisions. S. 2617, Ending the Carried Interest Loophole Act, to amend the Internal Revenue Code of 1986 to revise the treatment of partnership interests received in connection with the performance of services, and for other purposes, all provisions. Stepped-Up Basis at Death and Taxation of Unrealized Capital Gains at Death Support retaining current law providing for stepped-up basis at death and taxation of capital gains upon actual sale. H.R 2286, to amend the Internal Revenue Code of 1986 to treat property transferred by gift or at death as sold for fair market value, and for other purposes, all provisions. Foreign Investment in Real Property Tax Act (FIRPTA) H.R. 2210 (116th Congress), Invest in America Act, to amend the Internal Revenue Code of 1986 to repeal certain provisions applicable to foreign investment in United States real property, all provisions. H.R. 3123, Parity for Non-Traded REITs Act, to amend the Internal Revenue Code of 1986 to provide the same treatment to publicly offered, non-traded Real Estate Investment Trusts as is provided to exchange-traded Real Estate Investment Trusts under the Foreign Investment in Real Property Tax Act of 1980, all provisions.

Taxation of Pass-Through Entities Section 199A Qualified Business Income Tax Deduction: Oppose any reduction to or repeal of the 20-percent deduction for qualified business income under Section 199A, including phasing out the deduction above certain income thresholds. H.R. 1381, Main Street Tax Certainty Act, to amend the Internal Revenue Code of 1986 to make permanent the deduction for qualified business income, all provisions. S. 480, Main Street Tax Certainty Act, to amend the Internal Revenue Code of 1986 to make permanent the deduction for qualified business income, all provisions. Depreciation Rules Implementation of 30-year alternative depreciation system schedule for rental real estate placed in service prior to 2018 for taxpayers electing out of limits on interest deductibility as enacted in Public Law 116-260: Requested that the Treasury Department and the Internal Revenue Service issue guidance permitting an automatic change in the method of accounting for taxpayers that are impacted by the legislative changes made in P.L. 116-260. Also requested that guidance be issued consistent with the relief granted pursuant to Rev. Proc. 2020-22 and Rev. Proc. 2020-23, allowing partnerships subject to the BBA centralized partnership audit regime to file an amended return (Form 1065) and make a late Section 163(j) election and issue amended Schedules K for tax years beginning in 2018 and 2019. Low-Income Housing Tax Credit and Middle-Income Housing Tax Credit H.R. 2573, Affordable Housing Credit Improvement Act of 2021, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 1136, Affordable Housing Credit Improvement Act of 2021, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. H.R. 3077 (116th Congress), Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 1703 (116th Congress), Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 3365 (115th Congress), Middle-Income Housing Tax Credit Act of 2018, to amend the Internal Revenue Code of 1986 to provide a credit for middle-income housing, and for other purposes, all provisions. Department of the Treasury, Internal Revenue Service, 26 CFR Part 1, REG-119890-18, RIN 1454 BO92, Section 42, Low-Income Housing Credit Average Income Test Regulations Opportunity Zones Opportunity Zones: No bill introduced, but support legislative change reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes. Also, support maintaining current-law capital gains rate applicable to deferred capital gains invested in Opportunity Funds. Rehabilitation Tax Credit H.R. 1483, Revitalizing Economies, Housing, and Businesses Act of 2021 or the REHAB Act of 2021, to amend the Internal Revenue Code of 1986 to modify the rehabilitation credit, all provisions. Adaptive Reuse Discussed potential for tax incentives to spur adaptive reuse of non-residential commercial buildings into multifamily buildings. Energy Tax Incentives H.R. 848, Growing Renewable Energy and Efficiency Now Act of 2021 (GREEN Act of 2021), to amend the Internal Revenue Code of 1986 to provide incentives for renewable energy and energy efficiency, and for other purposes, Section 303: Energy Efficient Commercial Buildings Deduction; Section 304: Extension, Increase, and Modifications of New Energy Efficient Home Credit; and Section 405: Alternative Fuel Refueling Property Credit. H.R 2346, Energy Efficient Qualified Improvement Property Act of 2020, or the E-QUIP Act, to amend the Internal Revenue Code of 1986 to allow 10-year straight line depreciation for energy efficient qualified improvement property, and for other purposes, all provisions. S. 1298, Clean Energy for America Act, to amend the Internal Revenue Code of 1986 to provide tax incentives for increased investment in clean energy: Title II -- Incentives for Clean Transportation, Section 202: Transportation Electrification (portion of provision impacting the alternative fuel vehicle refueling property credit) and Title III -- Incentives for Energy Efficiency, Section 301: Credit for new energy efficient residential buildings and Section 303: Enhancement of energy efficient commercial buildings deduction; and Title VI -- Workforce Development Requirements, Section 601: Use of qualified apprentices. S. 2118, Clean Energy for America Act, to amend the Internal Revenue Code of 1986 to provide tax incentives for increased investment in clean energy: Title III -- Incentives for Energy Efficiency, Section 301: Credit for new energy efficient residential buildings and Section 303: Enhancement of energy efficient commercial buildings deduction; and Title V -- Workforce Development Requirements, Section 501: Use of qualified apprentices. Support long-term extension of New energy efficient home credit (IRC 45L). Support expansion of Energy efficient commercial buildings deduction (IRC 179D) to establish a sliding scale of energy improvements, which would help spur investment in energy efficient improvements in older buildings. Title I of the Energy Efficiency Tax Incentives Act (S. 2189 in the 113th Congress), amending IRC 179D to preserve the deductions application for new construction and public buildings, while also meaningfully incentivizing private-sector investment in building performance retrofits. Assessed efficacy of alternative fuel vehicle refueling property credit (IRC 30C) as it pertains to the multifamily industry. Davis-Bacon Oppose requiring Davis-Bacon for projects authorized as part of any forthcoming infrastructure legislation and to be required to be able to benefit from tax incentives, including energy tax incentives, generally. Infrastructure Support: Expanding the Low-Income Housing Tax Credit (H.R. 2573 / S. 1136), enacting the Middle-Income Housing Tax Credit, enacting the REHAB Act (H.R. 1483), Foreign Investment in Real Property Tax Act (FIRPTA) Repeal, enacting the Efficient Qualified Improvement Property Act of 2020 (E-QUIP) (H.R. 2346), making permanent the Section 45L New energy efficient home credit, and reducing the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes. Biden Tax Proposals Department of the Treasury, General Explanations of the Administration's Fiscal Year 2022 Revenue Proposals, American Families Plan: Increase the Top Marginal Income Tax Rate for High Earners, Reform the Taxation of Capital Income, Rationalize Net Investment Income and Self-Employment Contribution Act Taxes, Tax Carried (Profits) Interests as Ordinary Income, and Repeal Deferral of Gain from Like-Kind Exchanges. Biden Administration, The American Families Plan, tax proposals impacting: tax rates on individual income, capital gains tax rates, carried interest, the Medicare surtax on net investment income, stepped-up basis and taxation of unrealized capital gains at death, like-kind exchanges, and the limitation of excess business losses. Biden campaign tax proposals impacting multifamily housing (tax rates on individual income, capital gains tax rates, value of itemized deductions, elimination of stepped-up basis and taxation of unrealized capital gains at death, elimination of like-kind exchanges, expansion of Low-Income Housing Tax Credit, establishment of renter's tax credit, depreciation of multifamily property, and $15,000 first-time homebuyer tax credit). Like-Kind Exchanges Like-kind exchanges: Support retaining current law. Carried Interest Carried interest: NMHC believes that carried interest should be treated as a long-term capital gain if the underlying asset is held for at least one year. H.R. 1068, Carried Interest Fairness Act of 2021, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-thru entities, all provisions. S. 1598, Carried Interest Fairness Act of 2021, 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. Stepped-Up Basis at Death and Taxation of Unrealized Capital Gains at Death Support retaining current law providing for stepped-up basis at death and taxation of capital gains upon actual sale. H.R 2286, to amend the Internal Revenue Code of 1986 to treat property transferred by gift or at death as sold for fair market value, and for other purposes, all provisions. Senator Van Hollen Discussion Draft, Sensible Taxation and Equity Promotion Act of 2021, to amend the Internal Revenue Code of 1986 to realize gains from property at the time of death, and for other purposes, all provisions. Foreign Investment in Real Property Tax Act (FIRPTA) H.R. 2210 (116th Congress), Invest in America Act, to amend the Internal Revenue Code of 1986 to repeal certain provisions applicable to foreign investment in United States real property, all provisions. H.R. 3123, Parity for Non-Traded REITs Act, to amend the Internal Revenue Code of 1986 to provide the same treatment to publicly offered, non-traded Real Estate Investment Trusts as is provided to exchange-traded Real Estate Investment Trusts under the Foreign Investment in Real Property Tax Act of 1980, all provisions. Down payment Assistance H.R. 1360, American Dream Down payment Act, to amend the Internal Revenue Code of 1986 to establish qualified down payment savings programs, all provisions.

GSE Reform Bills LIHTC Improvements: Affordable Housing Credit Improvement Act (S. 1703 H.R. 3077); Middle Income Housing Tax Credit Act (S. 3365) Section 8 housing choice voucher reform Yes in My Backyard Act (S. 1919 H.R. 451) Manufactured Housing Modernization Act (S. 1804) GSA disposition of federal properties for housing purposes Housing is Infrastructure Act (H.R. 5187) Build more Housing Near Transit Act (H.R. 4307) CARES Act Tenant Anti-Eviction and Mortgage Forbearance Issues Federal Reserve Credit Facilities CARES Act eviction, forbearance matters

Client expense: $1,083,564 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Director of National Intelligence (ODNI), Energy, Dept of, Environmental Protection Agency (EPA), Federal Accounting Standards Advisory Board (FASAB), Federal Bureau of Investigation (FBI), Federal Deposit Insurance Corporation (FDIC), Federal Energy Regulatory Commission (FERC), 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), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, White House Office

COVID-19 Relief H.R. 1319 (Public Law 117-2), American Rescue Plan Act of 2021: Title III -- Committee on Banking, Housing, and Urban Affairs, Subtitle B -- Housing Provisions, Section 3201: Emergency Rental Assistance; Sec. 3202 Emergency Housing Vouchers; Sec. 3202 Emergency Assistance For Rural Housing Title IX -- Committee on Finance, Subtitle A -- Crisis Support for Unemployed Workers, Part 1 -- Extension of CARES Act Unemployment Provisions, all provisions; Part 4 -- Other Provisions, Section 9041: Extension of limitation on excess business losses of noncorporate taxpayers; Subtitle G -- Promoting Economic Security, Part 1 -- 2021 Recovery Rebates to Individuals, Section 9601: 2021 recovery rebates to individuals; Part 6 -- Employee Retention Credit, Section 9651: Extension of employee retention credit. Net Operating Losses and Limitation on Excess Business Losses of Non-corporate Taxpayers: Oppose modifying provisions impacting these provisions enacted as part of the CARES Act. Taxation of Pass-Through Entities H.R. 1381, Main Street Tax Certainty Act, to amend the Internal Revenue Code of 1986 to make permanent the deduction for qualified business income, all provisions. S. 480, Main Street Tax Certainty Act, to amend the Internal Revenue Code of 1986 to make permanent the deduction for qualified business income, all provisions. Depreciation Rules Implementation of 30-year alternative depreciation system schedule for rental real estate placed in service prior to 2018 for taxpayers electing out of limits on interest deductibility as enacted in Public Law 116-260: Requested that the Treasury Department and the Internal Revenue Service issue guidance permitting an automatic change in the method of accounting for taxpayers that are impacted by the legislative changes made in P.L. 116-260. Also requested that guidance be issued consistent with the relief granted pursuant to Rev. Proc. 2020-22 and Rev. Proc. 2020-23, allowing partnerships subject to the BBA centralized partnership audit regime to file an amended return (Form 1065) and make a late Section 163(j) election and issue amended Schedules K for tax years beginning in 2018 and 2019. H.R. 4685 (116th Congress), High Rise Fire Sprinkler Incentive Act of 2019, to amend the Internal Revenue Code of 1986 to classify certain automatic fire sprinkler system retrofits as 15-year property for purposes of depreciation, all provisions. Low-Income Housing Tax Credit, Middle-Income Housing Tax Credit, and Affordable Housing Tax Incentives Low-Income Housing Tax Credit: Support making permanent and augmenting by an additional 50 percent the increased credit authority enacted in March 2018 to enable the production of new units. Draft legislation, Affordable Housing Credit Improvement Act of 2021, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. H.R. 3077 (116th Congress), Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 1703 (116th Congress), Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. Requested Treasury and Internal Revenue Service extend deadlines to lease units in Low-Income Housing Tax Credit properties due to COVID-19-related hardships. Issue was addressed in Internal Revenue Service Notice 2021-12. H.R. 3479 (116th Congress), Save Affordable Housing Act of 2019, to amend the Internal Revenue Code of 1986 to repeal the qualified contract exception to the extended low-income housing commitment rules for purposes of the low-income housing credit, and for other purposes, all provisions. S. 1956 (116th Congress), Save Affordable Housing Act of 2019, to amend the Internal Revenue Code of 1986 to repeal the qualified contract exception to the extended low-income housing commitment rules for purposes of the low-income housing credit, and for other purposes, all provisions. S. 3365 (115th Congress), Middle-Income Housing Tax Credit Act of 2018, to amend the Internal Revenue Code of 1986 to provide a credit for middle-income housing, and for other purposes, all provisions. No legislative proposal but studied the efficacy of 80/20 bonds in the production of multifamily housing. Opportunity Zones Opportunity Zones: No bill introduced, but support legislative change reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes. Rehabilitation Tax Credit H.R. 1483, Revitalizing Economies, Housing, and Businesses Act of 2021 or the REHAB Act of 2021, to amend the Internal Revenue Code of 1986 to modify the rehabilitation credit, all provisions. Adaptive Reuse Discussed potential for tax incentives to spur adaptive reuse of non-residential commercial buildings into multifamily buildings. Energy Tax Incentives H.R 2346 Energy Efficient Qualified Improvement Property Act of 2020, or the E-QUIP Act, to amend the Internal Revenue Code of 1986 to allow 10-year straight line depreciation for energy efficient qualified improvement property, and for other purposes, all provisions. H.R. 848, Growing Renewable Energy and Efficiency Now Act of 2021 (GREEN Act of 2021), to amend the Internal Revenue Code of 1986 to provide incentives for renewable energy and energy efficiency, and for other purposes, Section 304: Extension, Increase, and Modifications of New Energy Efficient Home Credit. Section 179D Energy efficient commercial buildings deduction and its use by multifamily firms (for buildings with 4 or more stories) Section 45L Energy efficient home tax credit (buildings with 3 or fewer stories) Lead Safety S. 4908 (116th Congress), Home Lead Safety Tax Credit Act, to amend the Internal Revenue Code of 1986 to provide a tax credit for taxpayers who remove lead-based hazards, all provisions. Biden Tax Proposals Biden campaign tax proposals impacting multifamily housing (tax rates on individual income, capital gains tax rates, value of itemized deductions, elimination of stepped-up basis and taxation of unrealized capital gains at death, elimination of like-kind exchanges, expansion of Low-Income Housing Tax Credit, establishment of renter's tax credit, depreciation of multifamily property, and $15,000 first-time homebuyer tax credit). Tax Treatment of Capital Income Proposal by Senator Ron Wyden, Treat Wealth Like Wages, A plan to fix our broken tax code, ensure the wealthy pay their fair share, and protect Social Security. Like-Kind Exchanges Like-kind exchanges: Support retaining current law. Carried Interest Carried interest: NMHC believes that carried interest should be treated as a long-term capital gain if the underlying asset is held for at least one year. H.R. 1068, Carried Interest Fairness Act of 2021, 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. Stepped-Up Basis at Death and Taxation of Unrealized Capital Gains at Death Support retaining current law providing for stepped-up basis at death and taxation of capital gains upon actual sale. H.R 2286, to amend the Internal Revenue Code of 1986 to treat property transferred by gift or at death as sold for fair market value, and for other purposes, all provisions. Senator Van Hollen Discussion Draft, Sensible Taxation and Equity Promotion Act of 2021, to amend the Internal Revenue Code of 1986 to realize gains from property at the time of death, and for other purposes, all provisions. Estate Tax Estate Tax: Support making permanent the Estate Tax rules enacted as part of the Tax Cuts and Jobs Act of 2017.

GSE Reform Bills LIHTC Improvements: Affordable Housing Credit Improvement Act (S. 1703 H.R. 3077); Middle Income Housing Tax Credit Act (S. 3365) Section 8 housing choice voucher reform Yes in My Backyard Act (S. 1919 H.R. 451) Manufactured Housing Modernization Act (S. 1804) GSA disposition of federal properties for housing purposes Housing is Infrastructure Act (H.R. 5187) Build more Housing Near Transit Act (H.R. 4307) CARES Act Tenant Anti-Eviction and Mortgage Forbearance Issues Federal Reserve Credit Facilities CARES Act eviction, forbearance matters

Client expense: $1,056,891 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Director of National Intelligence (ODNI), Energy, Dept of, Environmental Protection Agency (EPA), Federal Accounting Standards Advisory Board (FASAB), Federal Bureau of Investigation (FBI), Federal Deposit Insurance Corporation (FDIC), Federal Energy Regulatory Commission (FERC), 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), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, White House Office

COVID-19 Tax Relief H.R. 133, Consolidated Appropriations Act, 2021, Division N -- Additional Coronavirus Response and Relief, Title II -- Assistance to Individuals, Families, and Businesses, Subtitle B -- COVID-related Tax Relief Act of 2020, Section 276: Clarification of tax treatment of forgiveness of covered loans; Division EE -- Taxpayer Certainty and Disaster Tax Relief Act of 2020: Title 1 -- Extension of Certain Expiring Provisions, Subtitle A -- Certain Provisions Made Permanent, Section 102: Energy efficient commercial buildings deduction, Subtitle C -- Extension of Certain Other Provisions, Section 146: Energy efficient homes credit; Title II -- Other Provisions, Section 201: Minimum low-income housing tax credit rate, Section 202: Depreciation of certain residential rental property over 30-year period, Section 206: Clarifications and technical improvements to CARES Act employee retention credit, and Section 207: Extension and modification of employee retention and rehiring tax credit. Draft Senate legislation, Emergency Coronavirus Relief Act of 2020, to provide emergency relief to American workers, families, and small businesses, impacted by the COVID-19 pandemic, Section 1102: Small Business Recovery (tax deductibility of business expenses financed through forgiven Paycheck Protection Program loans). H.R. 925, the Heroes Act, Division F -- Revenue Provisions, Title I -- Economic Stimulus: Section 101: Additional recovery rebates to individuals; Title II -- Provisions to Prevent Business Interruption: Section 201: Improvements to employee retention and rehiring credit and Section 203: Clarification of treatment of expenses paid or incurred with proceeds from certain grants and loans; and Title III -- Net Operating Losses: Section 301: Limitation on excess business losses of non-corporate taxpayers restored and made permanent and Section 302: Certain taxpayers allowed carryback of net operating losses arising in 2019 and 2020. H.R. 7615, Healthy Workplace Tax Credit, to provide a payroll tax credit for certain expenses associated with protecting employees from COVID-19, all provisions. H.R. 7079, Clean Start: Back to Work Tax Credit Act, to provide a tax credit to ensure that businesses are properly cleaned and disinfected when stay-at-home restrictions are lifted and to help prevent further infections, all provisions. H.R. 7222, Safe Reopening Tax Credit, to provide for a credit against employment taxes for certain virus transmission prevention expenses, and for other purposes, all provisions. H.R. 7216, Small Business PPE Tax Credit Act, to provide a tax credit for personal protective equipment to small businesses, non-profits, independent contractors, veterans organizations, and farmers, among other entities, in any year in which the President declares a national emergency relating to COVID-19, all provisions. S. 4214, Healthy Workplace Tax Credit, to provide a payroll tax credit for certain expenses associated with protecting employees from COVID-19, all provisions. S. 4178, to provide for a credit against employment taxes for certain workplace safety expenses, and for other purposes, all provisions. Low-Income Housing Tax Credit legislative proposals as part of COVID-19 relief, including enacting a minimum 4 percent Housing Credit rate; allowing developments to access 4 percent Housing Credits by lowering the 50 percent test; increasing the annual Housing Credit allocation by at least 50 percent, phased in over two years, and adjusted for inflation, beginning in 2021; providing additional basis boosts for properties such as those impacted by COVID-19 or bond-financed properties designated by state housing finance agencies; repealing the qualified contract option; and prohibiting qualified allocation plans from considering support or opposition to projects from local or elected officials. Signed coalition letter requesting the Treasury Department and Internal Revenue Service extend deadlines and make other accommodations applicable to the Low-Income Housing Tax Credit due to COVID-19. Requested Treasury Department and Internal Revenue Service extend deadlines to lease units in Low-Income Housing Tax Credit properties due to COVID-19-related hardships. Requested that COVID-19 relief legislation include a provision enabling taxpayers to deduct expenses funded by forgiven Paycheck Protection Program loans. The proposal would reverse IRS Notice 2020-32. Depreciation Rules H.R. 5313, Multifamily Depreciation Parity Act of 2019, to amend the Internal Revenue Code of 1986 to allow for certain residential rental property to be depreciated over a 30-year period, all provisions. S. 2984, Multifamily Depreciation Parity Act of 2019, to amend the Internal Revenue Code of 1986 to allow for certain residential rental property to be depreciated over a 30-year period, all provisions. Infrastructure Development H.R. 2, The Moving Forward Act, Division M -- Revenue Provisions: Title IV -- Green Energy, Subtitle C -- Green Energy and Efficiency Incentives for Individuals, Section 90423: Energy efficient commercial buildings deduction and Section 90424: Extension, increase, and modifications of new energy efficient home credit; Title VI -- Housing, Subtitle A -- Low-income Housing Tax Credit Improvements, all provisions. Infrastructure tax proposals: NMHC Supported: expanding and enhancing the Low-Income Housing Tax Credit; enacting the Middle-Income Housing Tax Credit; enacting a legislative change to reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes; and preserving current-law like-kind exchange rules. Low-Income Housing Tax Credit, Middle-Income Housing Tax Credit, and Affordable Housing Tax Incentives H.R. 3077, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 1703, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. Department of the Treasury, Internal Revenue Service, 26 CFR Part 1, REG-119890-18, RIN 1454 BO92, Section 42, Low-Income Housing Credit Average Income Test Regulations S. 3365, Middle-Income Housing Tax Credit Act of 2018 (115th Congress), to provide a credit for middle-income housing, and for other purposes, all provisions. H.R. 8533, Support Allowing Volume Exception for Federally-Assisted Housing Act or the SAVE Federally-Assisted Housing Act, to provide an exception to the volume cap requirement for private activity bonds used to finance the preservation, improvement, or replacement of certain Federally-assisted buildings, and for other purposes, all provisions. Energy We supported extending the IRC Section 45L New Energy Efficient Home Credit and extending and modifying the IRC Section 179D Energy Efficient Commercial Buildings Deduction to facilitate investments in improving the utility performance of existing properties. H.R. 8547, to make permanent the tax deduction for energy efficient commercial buildings, all provisions. H.R. 8930, Energy Efficient Qualified Improvement Property Act of 2020, or the E-QUIP Act, to amend the Internal Revenue Code to allow 10-year straight line depreciation for energy efficient qualified improvement property, and for other purposes, all provisions. Biden Tax Proposals Biden campaign tax proposals impacting multifamily housing (tax rates on individual income, tax rates on capital gains, value of itemized deductions, elimination of stepped-up basis at death and taxation of unrealized capital gains at death, elimination of like-kind exchanges, expansion of Low-Income Housing Tax Credit, establishment of renter's tax credit, depreciation of multifamily property, and $15,000 first-time homebuyer tax credit). Signed A Call to Invest in Our Neighborhoods (ACTION) Campaign memo to Biden Transition team requesting the incoming administration support: Affordable Housing Credit Improvement Act (H.R. 3077 / S. 1703); legislative proposals providing COVID-19 relief that establish a minimum 4 percent Low-Income Housing Tax Credit and reduce from 50 percent to 25 percent the amount of project costs that tax-exempt bonds must finance to qualify for low-income housing tax credits; and regulatory proposals to: (1) Publish new regulations to align Housing Credit program rules with the Violence Against Women Act, (2) Modify current Housing Credit casualty loss guidance to allow for more reasonable rebuilding periods, (3) Include relocation expenses in rehabilitation expenditures to ensure tenants' safety, and (4) Strengthen oversight by preventing "planned foreclosures" of Housing Credit developments. Stepped-Up Basis at Death Analysis of proposals to eliminate stepped-up basis at death and tax unrealized capital gains at death: Support retaining current law providing for stepped-up basis at death and taxation of capital gains upon actual sale. Like-Kind Exchanges Support maintaining current tax law relative to the tax treatment of 1031 Like-Kind Exchanges. Estate Tax Estate Tax: Support making permanent the Estate Tax rules enacted as part of the Tax Cuts and Jobs Act of 2017.

GSE Reform Bills LIHTC Improvements: Affordable Housing Credit Improvement Act (S.1703/HR3077); Middle Income Housing Tax Credit Act (S.3365) Section 8 housing choice voucher reform Yes in My Backyard Act (S.1919/HR451) Manufactured Housing Modernization Act (S.1804) GSA disposition of federal properties for housing purposes Housing is Infrastructure Act (H.R. 5187) Build more Housing Near Transit Act (H.R. 4307) CARES Act Tenant Ani-Eviction and Mortgage Forbearance Issues Federal Reserve Credit Facilities CARES Act eviction, forbearance matters

Client expense: $962,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Director of National Intelligence (ODNI), Energy, Dept of, Environmental Protection Agency (EPA), Federal Accounting Standards Advisory Board (FASAB), Federal Bureau of Investigation (FBI), Federal Deposit Insurance Corporation (FDIC), Federal Energy Regulatory Commission (FERC), 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), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, White House Office

GSE Reform Bills LIHTC Improvements: Affordable Housing Credit Improvement Act (S.1703/HR3077); Middle Income Housing Tax Credit Act (S.3365) Section 8 housing choice voucher reform Yes in My Backyard Act (S.1919/HR451) Manufactured Housing Modernization Act (S.1804) GSA disposition of federal properties for housing purposes Housing is Infrastructure Act (H.R. 5187) Build more Housing Near Transit Act (H.R. 4307) CARES Act Tenant Ani-Eviction and Mortgage Forbearance Issues Federal Reserve Credit Facilities CARES Act eviction, forbearance matters

Client expense: $1,200,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Director of National Intelligence (ODNI), Energy, Dept of, Environmental Protection Agency (EPA), Federal Accounting Standards Advisory Board (FASAB), Federal Bureau of Investigation (FBI), Federal Deposit Insurance Corporation (FDIC), Federal Energy Regulatory Commission (FERC), 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), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, White House Office

GSE Reform Bills LIHTC Improvements: Affordable Housing Credit Improvement Act (S.1703/HR3077); Middle Income Housing Tax Credit Act (S.3365) Section 8 housing choice voucher reform Yes in My Backyard Act (S.1919/HR451) Manufactured Housing Modernization Act (S.1804) GSA disposition of federal properties for housing purposes Housing is Infrastructure Act (H.R. 5187) Build more Housing Near Transit Act (H.R. 4307) CARES Act Tenant Ani-Eviction and Mortgage Forbearance Issues Federal Reserve Credit Facilities CARES Act eviction, forbearance matters

Client expense: $1,038,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Director of National Intelligence (ODNI), Energy, Dept of, Environmental Protection Agency (EPA), Federal Accounting Standards Advisory Board (FASAB), Federal Bureau of Investigation (FBI), Federal Deposit Insurance Corporation (FDIC), Federal Energy Regulatory Commission (FERC), 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), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, White House Office

COVID-19 Tax Relief H.R. 6800, Health and Economic Recovery Omnibus Emergency Solutions (HEROES) Act, Division B -- Revenue Provisions: Title I Economic Stimulus: Section 20101: Dependents taken into account in determining credit and rebates; Section 20111: Additional recovery rebates to individuals; and Section 20131: Child Tax Credit improvements for 2020. Title II -- Additional Relief for Workers: Section 20211: Improvements to Employee Retention Credit; Section 20212: Payroll credit for certain fixed expenses of employers subject to closure by reason of COVID-19; Section 20221: Extension of Credits; Section 20222: Repeal of reduced credit for certain leave; Section 20223: Increase in limitation on credit for paid family leave; Section 20231: Payroll tax deferral for recipients of certain loan forgiveness; and Section 20235: Clarification of treatment of expenses paid or incurred with proceeds from certain loans and grants. Title III: Net Operating Losses: Section 20301: Limitation on excess business losses of non-corporate taxpayers restored and made permanent; and Section 20302: Certain taxpayers allowed carryback of net operating losses arising in 2019 and 2020. Division E -- Continued assistance to unemployed workers, all provisions. Supported the following legislative tax proposals for any further Coronavirus relief package: Clarify that a 30-year depreciation period applies to multifamily buildings placed in service prior to 2018 for taxpayers electing out of limits on interest deductibility (H.R. 5313 / S. 2984): expand the Low-Income Housing Tax Credit; enact the Middle-Income Housing Tax Credit; reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes; repeal the Foreign Investment in Real Property Tax Act; extend the IRC Section 45L New Energy Efficient Home Credit; extend and modify the IRC Section 179D Energy Efficient Commercial Buildings Deduction to facilitate investments in improving the utility performance of existing properties; and provide a rehabilitation tax credit for rehabilitating multifamily housing near transit. With respect to expanding the Low-Income Housing Tax Credit, we requested Congress enact COVID-19 response legislation that would: Enact a minimum 4 percent Low-Income Housing Tax Credit rate; lower the 50 percent bond financing threshold for 4 percent Low-Income Housing Tax Credit developments; increase the annual Low-Income Housing Tax Credit by 50 percent; and provide additional basis boots for vulnerable properties impacted by COVID-19. Requested that Treasury Department and Internal Revenue Service take immediate action to provide deadline extensions and other necessary accommodations for the Low-Income Housing Tax Credit program in light of the severe disruptions the COVID-19 pandemic is having on development and construction activities and the ongoing operations of existing Housing Credit properties. With respect to Opportunity Zones, we also supported legislative proposals to: allow opportunity funds to raise capital from all sources, not just gain rolled over from a recently disposed investment; spur productive real estate investment in low-income communities by providing that a 50 percent increase in the basis of a building constitutes a substantial improvement of the property; provide certainty to potential Opportunity Zone investors by codifying the tax rate on deferred gain and extending current deadlines for the basis increase and recognition of deferred gain; and preserve the economic incentives of the original Opportunity Zone provisions by extending for two years the recognition date for deferred gain, and consequently, the deadlines that must be met in order to qualify for the increase in basis for gain rolled into an opportunity fund. Requested Treasury and Internal Revenue Service extend the deadlines to identify replacement property and / or complete like-kind exchanges per the relief described in Rev. Proc. 2018-58 and authorized under Internal Revenue Code Section 7508A. Department of the Treasury and Internal Revenue Service, Notice 2020-23, 26 CFR 601.601, Update to Notice 2020-18, Additional Relief for Taxpayers Affected by Ongoing Coronavirus Disease 2019 Pandemic, Provisions related to extending the 45-day identification period and 180-day closing period for Like-Kind Exchanges. Specifically, we sought clarification that with respect to like-kind exchanges described in Section 1031 that Section 17 of Rev. Proc. 2018-58 applies. We also requested that March 13, 2020, be deemed to be the beginning date of disaster relief under Section 17, that each day of the disaster period from March 13 to July 15, 2020 be treated as the date of the federally declared disaster, and that taxpayers with one like-kind exchange deadline falling within the Notice 2020-23 disaster period be permitted to an extension of both deadlines. Internal Revenue Service Notice 2020-32 regarding tax deductibility of expenses related to Paycheck Protection Program loans H.R. 6821, Small Business Expense Protection Act of 2020, to clarify for purposes of the Internal Revenue Code of 1986 that receipt of coronavirus assistance does not affect the tax treatment of ordinary business expenses, all provisions. S. 3612, Small Business Expense Protection Act of 2020, to clarify for purposes of the Internal Revenue Code of 1986 that receipt of coronavirus assistance does not affect the tax treatment of ordinary business expenses, all provisions. Coronavirus Aid, Relief, and Economic Security (CARES) Act (Public Law 116-136), Section 2303: Modifications for net operating losses; and Section 2304: Modification of limitation on losses for taxpayers other than corporations. Draft legislative proposal to amend the Internal Revenue Code of 1986 to provide a special allowance for certain real property placed in service during the COVID-19 pandemic. Considered legislative proposal to provide charitable tax deduction for real estate owners providing housing to COVID-19 first responders. Considered legislative proposals regarding additional carryback of General Business Credit Depreciation Rules H.R. 5313, Multifamily Depreciation Parity Act of 2019, to amend the Internal Revenue Code of 1986 to allow for certain residential rental property to be depreciated over a 30-year period, all provisions. S. 2984, Multifamily Depreciation Parity Act of 2019, to amend the Internal Revenue Code of 1986 to allow for certain residential rental property to be depreciated over a 30-year period, all provisions. Infrastructure Development H.R. 2, The Moving Forward Act, Division M -- Revenue Provisions: Title IV -- Green Energy, Subtitle C -- Green Energy and Efficiency Incentives for Individuals, Section 90423: Energy efficient commercial buildings deduction and Section 90424: Extension, increase, and modifications of new energy efficient home credit; Title VI -- Housing, Subtitle A -- Low-income Housing Tax Credit Improvements, all provisions. H.R. 6175, Revitalizing Economies, Housing, and Businesses Act of 2020 or the REHAB Act of 2020, to amend the Internal Revenue Code of 1986 to modify the rehabilitation credit, all provisions. Supported infrastructure tax incentives to: expand the Low-Income Housing Tax Credit; enact the Middle-Income Housing Tax Credit; reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes; repeal the Foreign Investment in Real Property Tax Act; extend the IRC Section 45L New Energy Efficient Home Credit; extending and modify the IRC Section 179D Energy Efficient Commercial Buildings Deduction to facilitate investments in improving the utility performance of existing properties; and provide a rehabilitation tax credit for rehabilitating multifamily housing near transit. Low-Income Housing Tax Credit and Middle-Income Housing Tax Credit S. 4078, Emergency Affordable Housing Act, to amend the Internal Revenue Code of 1986 to improve the low-income housing credit and provide relief relating to the coronavirus emergency, and for other purposes, all provisions. H.R. 3077, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 1703, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 3365 (115th Congress), Middle-Income Housing Tax Credit Act of 2018, to provide a credit for middle-income housing, and for other purposes, all provisions. Energy We support extending the IRC Section 45L New Energy Efficient Home Credit and extending and modifying the IRC Section 179D Energy Efficient Commercial Buildings Deduction to facilitate investments in improving the utility performance of existing properties H.R. 4646, New Home Energy Efficiency Act, to amend the Internal Revenue Code of 1986 to extend and update the new energy efficient home credit, all provisions. S. 2595, New Home Energy Efficiency Act, to amend the Internal Revenue Code of 1986 to extend and update the new energy efficient home credit, all provisions. Draft legislation, Growing Renewable Energy and Efficiency Now Act of 2019, or the GREEN Act of 2019, to amend the Internal Revenue Code to promote green energy, Section 303: Energy efficient commercial buildings deduction and Section 304: Extension, increase, and modifications of new energy efficient home credit. Draft legislation, Energy Efficient Qualified Improvement Property Act of 2019, or the E-QuIP Act, to amend the Internal Revenue Code to allow 10-year straight line depreciation for energy efficient qualified improvement property, and for other purposes, all provisions. Like-Kind Exchanges Support maintaining current tax law relative to the tax treatment of 1031 Like-Kind Exchanges. Department of the Treasury and Internal Revenue Service, REG 117589-18, RIN 1545-BP02, 26 CFR Part 1, Statutory Limitations on Like-Kind Exchanges Foreign Investment in Real Property Tax Act (FIRPTA) H.R. 2210, Invest in America Act, to amend the Internal Revenue Code of 1986 to repeal certain provisions applicable to foreign investment in United States real property, all provisions.

COVID-19 Tax Relief H.R. 6800, Health and Economic Recovery Omnibus Emergency Solutions (HEROES) Act, Division B -- Revenue Provisions: Title I Economic Stimulus: Section 20101: Dependents taken into account in determining credit and rebates; Section 20111: Additional recovery rebates to individuals; and Section 20131: Child Tax Credit improvements for 2020. Title II -- Additional Relief for Workers: Section 20211: Improvements to Employee Retention Credit; Section 20212: Payroll credit for certain fixed expenses of employers subject to closure by reason of COVID-19; Section 20221: Extension of Credits; Section 20222: Repeal of reduced credit for certain leave; Section 20223: Increase in limitation on credit for paid family leave; Section 20231: Payroll tax deferral for recipients of certain loan forgiveness; and Section 20235: Clarification of treatment of expenses paid or incurred with proceeds from certain loans and grants. Title III: Net Operating Losses: Section 20301: Limitation on excess business losses of non-corporate taxpayers restored and made permanent; and Section 20302: Certain taxpayers allowed carryback of net operating losses arising in 2019 and 2020. Division E -- Continued assistance to unemployed workers, all provisions. Supported the following legislative tax proposals for any further Coronavirus relief package: Clarify that a 30-year depreciation period applies to multifamily buildings placed in service prior to 2018 for taxpayers electing out of limits on interest deductibility (H.R. 5313 / S. 2984): expand the Low-Income Housing Tax Credit; enact the Middle-Income Housing Tax Credit; reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes; repeal the Foreign Investment in Real Property Tax Act; extend the IRC Section 45L New Energy Efficient Home Credit; extend and modify the IRC Section 179D Energy Efficient Commercial Buildings Deduction to facilitate investments in improving the utility performance of existing properties; and provide a rehabilitation tax credit for rehabilitating multifamily housing near transit. With respect to expanding the Low-Income Housing Tax Credit, we requested Congress enact COVID-19 response legislation that would: Enact a minimum 4 percent Low-Income Housing Tax Credit rate; lower the 50 percent bond financing threshold for 4 percent Low-Income Housing Tax Credit developments; increase the annual Low-Income Housing Tax Credit by 50 percent; and provide additional basis boots for vulnerable properties impacted by COVID-19. Requested that Treasury Department and Internal Revenue Service take immediate action to provide deadline extensions and other necessary accommodations for the Low-Income Housing Tax Credit program in light of the severe disruptions the COVID-19 pandemic is having on development and construction activities and the ongoing operations of existing Housing Credit properties. With respect to Opportunity Zones, we also supported legislative proposals to: allow opportunity funds to raise capital from all sources, not just gain rolled over from a recently disposed investment; spur productive real estate investment in low-income communities by providing that a 50 percent increase in the basis of a building constitutes a substantial improvement of the property; provide certainty to potential Opportunity Zone investors by codifying the tax rate on deferred gain and extending current deadlines for the basis increase and recognition of deferred gain; and preserve the economic incentives of the original Opportunity Zone provisions by extending for two years the recognition date for deferred gain, and consequently, the deadlines that must be met in order to qualify for the increase in basis for gain rolled into an opportunity fund. Requested Treasury and Internal Revenue Service extend the deadlines to identify replacement property and / or complete like-kind exchanges per the relief described in Rev. Proc. 2018-58 and authorized under Internal Revenue Code Section 7508A. Department of the Treasury and Internal Revenue Service, Notice 2020-23, 26 CFR 601.601, Update to Notice 2020-18, Additional Relief for Taxpayers Affected by Ongoing Coronavirus Disease 2019 Pandemic, Provisions related to extending the 45-day identification period and 180-day closing period for Like-Kind Exchanges. Specifically, we sought clarification that with respect to like-kind exchanges described in Section 1031 that Section 17 of Rev. Proc. 2018-58 applies. We also requested that March 13, 2020, be deemed to be the beginning date of disaster relief under Section 17, that each day of the disaster period from March 13 to July 15, 2020 be treated as the date of the federally declared disaster, and that taxpayers with one like-kind exchange deadline falling within the Notice 2020-23 disaster period be permitted to an extension of both deadlines. Internal Revenue Service Notice 2020-32 regarding tax deductibility of expenses related to Paycheck Protection Program loans H.R. 6821, Small Business Expense Protection Act of 2020, to clarify for purposes of the Internal Revenue Code of 1986 that receipt of coronavirus assistance does not affect the tax treatment of ordinary business expenses, all provisions. S. 3612, Small Business Expense Protection Act of 2020, to clarify for purposes of the Internal Revenue Code of 1986 that receipt of coronavirus assistance does not affect the tax treatment of ordinary business expenses, all provisions. Coronavirus Aid, Relief, and Economic Security (CARES) Act (Public Law 116-136), Section 2303: Modifications for net operating losses; and Section 2304: Modification of limitation on losses for taxpayers other than corporations. Draft legislative proposal to amend the Internal Revenue Code of 1986 to provide a special allowance for certain real property placed in service during the COVID-19 pandemic. Considered legislative proposal to provide charitable tax deduction for real estate owners providing housing to COVID-19 first responders. Considered legislative proposals regarding additional carryback of General Business Credit Depreciation Rules H.R. 5313, Multifamily Depreciation Parity Act of 2019, to amend the Internal Revenue Code of 1986 to allow for certain residential rental property to be depreciated over a 30-year period, all provisions. S. 2984, Multifamily Depreciation Parity Act of 2019, to amend the Internal Revenue Code of 1986 to allow for certain residential rental property to be depreciated over a 30-year period, all provisions. Infrastructure Development H.R. 2, The Moving Forward Act, Division M -- Revenue Provisions: Title IV -- Green Energy, Subtitle C -- Green Energy and Efficiency Incentives for Individuals, Section 90423: Energy efficient commercial buildings deduction and Section 90424: Extension, increase, and modifications of new energy efficient home credit; Title VI -- Housing, Subtitle A -- Low-income Housing Tax Credit Improvements, all provisions. H.R. 6175, Revitalizing Economies, Housing, and Businesses Act of 2020 or the REHAB Act of 2020, to amend the Internal Revenue Code of 1986 to modify the rehabilitation credit, all provisions. Supported infrastructure tax incentives to: expand the Low-Income Housing Tax Credit; enact the Middle-Income Housing Tax Credit; reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes; repeal the Foreign Investment in Real Property Tax Act; extend the IRC Section 45L New Energy Efficient Home Credit; extending and modify the IRC Section 179D Energy Efficient Commercial Buildings Deduction to facilitate investments in improving the utility performance of existing properties; and provide a rehabilitation tax credit for rehabilitating multifamily housing near transit. Low-Income Housing Tax Credit and Middle-Income Housing Tax Credit S. 4078, Emergency Affordable Housing Act, to amend the Internal Revenue Code of 1986 to improve the low-income housing credit and provide relief relating to the coronavirus emergency, and for other purposes, all provisions. H.R. 3077, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 1703, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 3365 (115th Congress), Middle-Income Housing Tax Credit Act of 2018, to provide a credit for middle-income housing, and for other purposes, all provisions. Energy We support extending the IRC Section 45L New Energy Efficient Home Credit and extending and modifying the IRC Section 179D Energy Efficient Commercial Buildings Deduction to facilitate investments in improving the utility performance of existing properties H.R. 4646, New Home Energy Efficiency Act, to amend the Internal Revenue Code of 1986 to extend and update the new energy efficient home credit, all provisions. S. 2595, New Home Energy Efficiency Act, to amend the Internal Revenue Code of 1986 to extend and update the new energy efficient home credit, all provisions. Draft legislation, Growing Renewable Energy and Efficiency Now Act of 2019, or the GREEN Act of 2019, to amend the Internal Revenue Code to promote green energy, Section 303: Energy efficient commercial buildings deduction and Section 304: Extension, increase, and modifications of new energy efficient home credit. Draft legislation, Energy Efficient Qualified Improvement Property Act of 2019, or the E-QuIP Act, to amend the Internal Revenue Code to allow 10-year straight line depreciation for energy efficient qualified improvement property, and for other purposes, all provisions. Like-Kind Exchanges Support maintaining current tax law relative to the tax treatment of 1031 Like-Kind Exchanges. Department of the Treasury and Internal Revenue Service, REG 117589-18, RIN 1545-BP02, 26 CFR Part 1, Statutory Limitations on Like-Kind Exchanges Foreign Investment in Real Property Tax Act (FIRPTA) H.R. 2210, Invest in America Act, to amend the Internal Revenue Code of 1986 to repeal certain provisions applicable to foreign investment in United States real property, all provisions.

Depreciation Rules H.R. 5313, Multifamily Depreciation Parity Act of 2019, to amend the Internal Revenue Code of 1986 to allow for certain residential rental property to be depreciated over a 30-year period, all provisions. S. 2984, Multifamily Depreciation Parity Act of 2019, to amend the Internal Revenue Code of 1986 to allow for certain residential rental property to be depreciated over a 30-year period, all provisions. Business Interest Deductibility Department of Treasury and Internal Revenue Service, 26 CFR Part 1, REG-106089-18, RIN 1545-BO73, Limitation on Deduction for Business Interest Expense, issues pertaining to: (1) the interaction between the small business exception and the real estate trade or business election (as well as resulting impacts on the depreciation of multifamily buildings); and (2) the application of the REIT safe harbor to certain controlled partnerships. Opportunity Zones Opportunity Zones: No bill introduced but support legislative change to reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone substantial improvement purposes. S. 2787, Opportunity Zone Reporting and Reform Act, to amend the Internal Revenue Code of 1986 to require reporting for qualified opportunity funds, to make modifications to opportunity zones, and for other purposes, all provisions. Low-Income Housing Tax Credit, Middle-Income Housing Tax Credit, and Incentives for Housing Affordability and Infrastructure Development H.R. 3077, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 1703, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 3365 (115th Congress), Middle-Income Housing Tax Credit Act of 2018, to provide a credit for middle-income housing, and for other purposes, all provisions. H.R. 6175, Revitalizing Economies, Housing, and Businesses Act of 2020 or the REHAB Act of 2020, to amend the Internal Revenue Code of 1986 to modify the rehabilitation credit, all provisions. Draft legislative proposal to amend the Internal Revenue Code of 1986 to provide a special allowance for certain real property placed in service during the COVID-19 pandemic. Support infrastructure bill including tax incentives to: expand the Low-Income Housing Tax Credit; enact the Middle-Income Housing Tax Credit; reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes; repeal the Foreign Investment in Real Property Tax Act; extend the IRC Section 45L New Energy Efficient Home Credit; extending and modify the IRC Section 179D Energy Efficient Commercial Buildings Deduction to facilitate investments in improving the utility performance of existing properties; and provide a rehabilitation tax credit for rehabilitating multifamily housing near transit. Energy We support extending the IRC Section 45L New Energy Efficient Home Credit and extending and modifying the IRC Section 179D Energy Efficient Commercial Buildings Deduction to facilitate investments in improving the utility performance of existing properties H.R. 4506, Home Energy Savings Act, to amend the Internal Revenue Code of 1986 to extend and update the credit for nonbusiness energy property, all provisions. H.R. 4646, New Home Energy Efficiency Act, to amend the Internal Revenue Code of 1986 to extend and update the new energy efficient home credit, all provisions. S. 2588, Home Energy Savings Act, to amend the Internal Revenue Code of 1986 to extend and update the credit for nonbusiness energy property, all provisions. S. 2595, New Home Energy Efficiency Act, to amend the Internal Revenue Code of 1986 to extend and update the new energy efficient home credit, all provisions. Draft legislation, Growing Renewable Energy and Efficiency Now Act of 2019, or the GREEN Act of 2019, to amend the Internal Revenue Code to promote green energy, Section 303: Energy efficient commercial buildings deduction and Section 304: Extension, increase, and modifications of new energy efficient home credit. Draft legislation, Energy Efficient Qualified Improvement Property Act of 2019, or the E-QuIP Act, to amend the Internal Revenue Code to allow 10-year straight line depreciation for energy efficient qualified improvement property, and for other purposes, all provisions. Fire Sprinklers H.R. 4685, High Rise Fire Sprinkler Incentive Act of 2019, to amend the Internal Revenue Code of 1986 to classify certain automatic fire sprinkler system retrofits as 15-year property for purposes of depreciation, all provisions. Tax Treatment of Capital Income Proposal by Senate Finance Committee Ranking Member Ron Wyden, Treat Wealth Like Wages, A plan to fix our broken tax code, ensure the wealthy pay their fair share, and protect Social Security. Like-Kind Exchanges Support maintaining current tax law relative to the tax treatment of 1031 Like-Kind Exchanges. Letter to Treasury and Internal Revenue Service requesting that the deadlines to identify replacement property and / or complete like-kind exchanges be extended per the relief described in Rev. Proc. 2018-58 and authorized under Internal Revenue Code 7508A. Carried Interest H.R. 1735, Carried Interest Fairness Act of 2019, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-through entities, all provisions. S. 781, Carried Interest Fairness Act of 2019, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-through entities, all provisions. S. 1639, Ending the Carried Interest Loophole Act, to amend the Internal Revenue Code of 1986 to revise the treatment of partnership interests received in connection with the performance of services, and for other purposes, all provisions. Foreign Investment in Real Property Tax Act (FIRPTA) H.R. 2210, Invest in America Act, to amend the Internal Revenue Code of 1986 to repeal certain provisions applicable to foreign investment in United States real property, all provisions.

Depreciation Rules H.R. 5313, Multifamily Depreciation Parity Act of 2019, to amend the Internal Revenue Code of 1986 to allow for certain residential rental property to be depreciated over a 30-year period, all provisions. S. 2984, Multifamily Depreciation Parity Act of 2019, to amend the Internal Revenue Code of 1986 to allow for certain residential rental property to be depreciated over a 30-year period, all provisions. Business Interest Deductibility Department of Treasury and Internal Revenue Service, 26 CFR Part 1, REG-106089-18, RIN 1545-BO73, Limitation on Deduction for Business Interest Expense, issues pertaining to: (1) the interaction between the small business exception and the real estate trade or business election (as well as resulting impacts on the depreciation of multifamily buildings); and (2) the application of the REIT safe harbor to certain controlled partnerships. Opportunity Zones Opportunity Zones: No bill introduced but support legislative change to reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone substantial improvement purposes. S. 2787, Opportunity Zone Reporting and Reform Act, to amend the Internal Revenue Code of 1986 to require reporting for qualified opportunity funds, to make modifications to opportunity zones, and for other purposes, all provisions. Low-Income Housing Tax Credit, Middle-Income Housing Tax Credit, and Incentives for Housing Affordability and Infrastructure Development H.R. 3077, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 1703, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 3365 (115th Congress), Middle-Income Housing Tax Credit Act of 2018, to provide a credit for middle-income housing, and for other purposes, all provisions. H.R. 6175, Revitalizing Economies, Housing, and Businesses Act of 2020 or the REHAB Act of 2020, to amend the Internal Revenue Code of 1986 to modify the rehabilitation credit, all provisions. Draft legislative proposal to amend the Internal Revenue Code of 1986 to provide a special allowance for certain real property placed in service during the COVID-19 pandemic. Support infrastructure bill including tax incentives to: expand the Low-Income Housing Tax Credit; enact the Middle-Income Housing Tax Credit; reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes; repeal the Foreign Investment in Real Property Tax Act; extend the IRC Section 45L New Energy Efficient Home Credit; extending and modify the IRC Section 179D Energy Efficient Commercial Buildings Deduction to facilitate investments in improving the utility performance of existing properties; and provide a rehabilitation tax credit for rehabilitating multifamily housing near transit. Energy We support extending the IRC Section 45L New Energy Efficient Home Credit and extending and modifying the IRC Section 179D Energy Efficient Commercial Buildings Deduction to facilitate investments in improving the utility performance of existing properties H.R. 4506, Home Energy Savings Act, to amend the Internal Revenue Code of 1986 to extend and update the credit for nonbusiness energy property, all provisions. H.R. 4646, New Home Energy Efficiency Act, to amend the Internal Revenue Code of 1986 to extend and update the new energy efficient home credit, all provisions. S. 2588, Home Energy Savings Act, to amend the Internal Revenue Code of 1986 to extend and update the credit for nonbusiness energy property, all provisions. S. 2595, New Home Energy Efficiency Act, to amend the Internal Revenue Code of 1986 to extend and update the new energy efficient home credit, all provisions. Draft legislation, Growing Renewable Energy and Efficiency Now Act of 2019, or the GREEN Act of 2019, to amend the Internal Revenue Code to promote green energy, Section 303: Energy efficient commercial buildings deduction and Section 304: Extension, increase, and modifications of new energy efficient home credit. Draft legislation, Energy Efficient Qualified Improvement Property Act of 2019, or the E-QuIP Act, to amend the Internal Revenue Code to allow 10-year straight line depreciation for energy efficient qualified improvement property, and for other purposes, all provisions. Fire Sprinklers H.R. 4685, High Rise Fire Sprinkler Incentive Act of 2019, to amend the Internal Revenue Code of 1986 to classify certain automatic fire sprinkler system retrofits as 15-year property for purposes of depreciation, all provisions. Tax Treatment of Capital Income Proposal by Senate Finance Committee Ranking Member Ron Wyden, Treat Wealth Like Wages, A plan to fix our broken tax code, ensure the wealthy pay their fair share, and protect Social Security. Like-Kind Exchanges Support maintaining current tax law relative to the tax treatment of 1031 Like-Kind Exchanges. Letter to Treasury and Internal Revenue Service requesting that the deadlines to identify replacement property and / or complete like-kind exchanges be extended per the relief described in Rev. Proc. 2018-58 and authorized under Internal Revenue Code 7508A. Carried Interest H.R. 1735, Carried Interest Fairness Act of 2019, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-through entities, all provisions. S. 781, Carried Interest Fairness Act of 2019, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-through entities, all provisions. S. 1639, Ending the Carried Interest Loophole Act, to amend the Internal Revenue Code of 1986 to revise the treatment of partnership interests received in connection with the performance of services, and for other purposes, all provisions. Foreign Investment in Real Property Tax Act (FIRPTA) H.R. 2210, Invest in America Act, to amend the Internal Revenue Code of 1986 to repeal certain provisions applicable to foreign investment in United States real property, all provisions.

GSE Reform Bills LIHTC Improvements: Affordable Housing Credit Improvement Act (S.1703/HR3077); Middle Income Housing Tax Credit Act (S.3365) Section 8 housing choice voucher reform Yes in My Backyard Act (S.1919/HR451) Manufactured Housing Modernization Act (S.1804) GSA disposition of federal properties for housing purposes Housing is Infrastructure Act (H.R. 5187) Build more Housing Near Transit Act (H.R. 4307) CARES Act Tenant Ani-Eviction and Mortgage Forbearance Issues Federal Reserve Credit Facilities

Client expense: $883,000 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Director of National Intelligence (ODNI), Energy, Dept of, Environmental Protection Agency (EPA), Federal Accounting Standards Advisory Board (FASAB), Federal Bureau of Investigation (FBI), Federal Deposit Insurance Corporation (FDIC), Federal Energy Regulatory Commission (FERC), 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), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), Small Business Administration (SBA), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, White House Office

Depreciation Rules Requested Congress pass legislation to clarify that firms electing out of limits on business interest deductibility may depreciate multifamily buildings placed in service prior to 2018 over 30 years. H.R. 5313, Multifamily Depreciation Parity Act of 2019, to amend the Internal Revenue Code of 1986 to allow for certain residential rental property to be depreciated over a 30-year period, all provisions. S. 2984, Multifamily Depreciation Parity Act of 2019, to amend the Internal Revenue Code of 1986 to allow for certain residential rental property to be depreciated over a 30-year period, all provisions. Business Interest Deductibility Department of Treasury and Internal Revenue Service, 26 CFR Part 1, REG-106089-18, RIN 1545-BO73, Limitation on Deduction for Business Interest Expense, issues pertaining to: (1) the interaction between the small business exception and the real estate trade or business election (as well as resulting impacts on the depreciation of multifamily buildings); and (2) the application of the REIT safe harbor to certain controlled partnerships. Opportunity Zones Department of the Treasury and Internal Revenue Service, 26 CFR Part 1, REG-120186-18, RIN 1545-BP04, Investing in Qualified Opportunity Funds. Note: This proposed rule, as well as proposed rule: Department of Treasury and Internal Revenue Service, 26 CFR Part 1, REG-115420-18, RIN 1545-BP03, Investing in Qualified Opportunity Funds, became a final regulation on December 19, 2019: Department of the Treasury and Internal Revenue Service, 26 CFR Part 1, TD 9889, RIN 1545-BP04, Investing in Qualified Opportunity Funds. Opportunity Zones: No bill introduced but support legislative change to reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone substantial improvement purposes. H.R. 2593, to require the Secretary of the Treasury to collect data and issue a report on the opportunity zone tax incentives enacted by the 2017 tax reform legislation, and for other purposes, all provisions. H.R. 4011, to amend the Internal Revenue Code of 1986 to require lead remediation for qualified opportunity zone property originally constructed before January 1, 1978. H.R. 5011, Opportunity Zone Accountability and Transparency Act, to amend the Internal Revenue Code of 1986 to require reporting by qualified opportunity funds, all provisions. S. 1344, to require the Secretary of the Treasury to collect data and issue a report on the opportunity zone tax incentives enacted by the 2017 tax reform legislation, and for other purposes, all provisions. S. 2787, Opportunity Zone Reporting and Reform Act, to amend the Internal Revenue Code of 1986 to require reporting for qualified opportunity funds, to make modifications to opportunity zones, and for other purposes, all provisions. S. 2994, Improving and Reinstating the Monitoring, Prevention, Accountability, Certification, and Transparency Provisions of Opportunity Zones or the IMPACT Act, to amend the Internal Revenue Code of 1986 to require information reporting with respect to the qualified opportunity zone tax incentives enacted by the 2017 tax reform legislation, to require public reports related to such tax incentives, and for other purposes, all provisions. Low-Income Housing Tax Credit, Middle-Income Housing Tax Credit, and Incentives for Housing Affordability and Infrastructure Development H.R. 3077, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 1703, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 3365 (115th Congress), Middle-Income Housing Tax Credit Act of 2018, to provide a credit for middle-income housing, and for other purposes, all provisions. Requested that any infrastructure bill include tax incentives to: expand the Low-Income Housing Tax Credit; enact the Middle-Income Housing Tax Credit; reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes; repeal the Foreign Investment in Real Property Tax Act; extend the IRC Section 45L New Energy Efficient Home Credit; and extend and modify the IRC Section 179D Energy Efficient Commercial Buildings Deduction to facilitate investments in improving the utility performance of existing properties. Legislative proposal, to amend the Internal Revenue Code of 1986 to permit certain contributions by governmental entities to be treated as contributions of capital and to exclude from gross income contributions of capital of a partnership. Energy H.R. 1865, Further Consolidated Appropriations Act, 2020 (became Public Law 116-94), Division Q -- Revenue Provisions, Taxpayer Certainty and Disaster Relief Act of 2019, Section 129: Energy efficient homes credit and Section 131: Energy efficient commercial buildings deduction. H.R. 4506, Home Energy Savings Act, to amend the Internal Revenue Code of 1986 to extend and update the credit for nonbusiness energy property, all provisions. H.R. 4646, New Home Energy Efficiency Act, to amend the Internal Revenue Code of 1986 to extend and update the new energy efficient home credit, all provisions. S. 2588, Home Energy Savings Act, to amend the Internal Revenue Code of 1986 to extend and update the credit for nonbusiness energy property, all provisions. S. 2595, New Home Energy Efficiency Act, to amend the Internal Revenue Code of 1986 to extend and update the new energy efficient home credit, all provisions. Draft legislation, Growing Renewable Energy and Efficiency Now Act of 2019, or the GREEN Act of 2019, to amend the Internal Revenue Code to promote green energy, Section 303: Energy efficient commercial buildings deduction and Section 304: Extension, increase, and modifications of new energy efficient home credit. Draft legislation, Energy Efficient Qualified Improvement Property Act of 2019, or the E-QuIP Act, to amend the Internal Revenue Code to allow 10-year straight line depreciation for energy efficient qualified improvement property, and for other purposes, all provisions. Estate Tax Support making permanent the Estate Tax rules enacted as part of the Tax Cuts and Jobs Act of 2017. Tax Administration Letter to Treasury Department and IRS requesting a delay of the implementation of the 2019 Draft Form 1065 and Schedule K-1 by at least one year (until 2020) to allow for a full public review and comment process. Carried Interest H.R. 1735, Carried Interest Fairness Act of 2019, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-through entities, all provisions. S. 781, Carried Interest Fairness Act of 2019, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-through entities, all provisions. S. 1639, Ending the Carried Interest Loophole Act, to amend the Internal Revenue Code of 1986 to revise the treatment of partnership interests received in connection with the performance of services, and for other purposes, all provisions. Foreign Investment in Real Property Tax Act (FIRPTA) H.R. 2210, Invest in America Act, to amend the Internal Revenue Code of 1986 to repeal certain provisions applicable to foreign investment in United States real property, all provisions.

GSE Reform Bills LIHTC Improvements: Affordable Housing Credit Improvement Act (S.1703/HR3077); Middle Income Housing Tax Credit Act (S.3365) Section 8 housing choice voucher reform Yes in My Backyard Act (S.1919/HR451) Manufactured Housing Modernization Act (S.1804) GSA disposition of federal properties for housing purposes

Client expense: $1,154,845 · Firm income: Not reported

Government targets: Commerce, Dept of (DOC), Commodity Futures Trading Commission (CFTC), Director of National Intelligence (ODNI), Energy, Dept of, Environmental Protection Agency (EPA), Federal Accounting Standards Advisory Board (FASAB), Federal Bureau of Investigation (FBI), Federal Deposit Insurance Corporation (FDIC), Federal Energy Regulatory Commission (FERC), 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), Office of the Comptroller of the Currency (OCC), SENATE, Securities & Exchange Commission (SEC), State, Dept of (DOS), Transportation, Dept of (DOT), Treasury, Dept of, White House Office

Depreciation Rules Requested Congress pass legislation to clarify that firms electing out of limits on business interest deductibility may depreciate multifamily buildings placed in service prior to 2018 over 30 years. H.R. 5313, Multifamily Depreciation Parity Act of 2019, to amend the Internal Revenue Code of 1986 to allow for certain residential rental property to be depreciated over a 30-year period, all provisions. S. 2984, Multifamily Depreciation Parity Act of 2019, to amend the Internal Revenue Code of 1986 to allow for certain residential rental property to be depreciated over a 30-year period, all provisions. Business Interest Deductibility Department of Treasury and Internal Revenue Service, 26 CFR Part 1, REG-106089-18, RIN 1545-BO73, Limitation on Deduction for Business Interest Expense, issues pertaining to: (1) the interaction between the small business exception and the real estate trade or business election (as well as resulting impacts on the depreciation of multifamily buildings); and (2) the application of the REIT safe harbor to certain controlled partnerships. Opportunity Zones Department of the Treasury and Internal Revenue Service, 26 CFR Part 1, REG-120186-18, RIN 1545-BP04, Investing in Qualified Opportunity Funds. Note: This proposed rule, as well as proposed rule: Department of Treasury and Internal Revenue Service, 26 CFR Part 1, REG-115420-18, RIN 1545-BP03, Investing in Qualified Opportunity Funds, became a final regulation on December 19, 2019: Department of the Treasury and Internal Revenue Service, 26 CFR Part 1, TD 9889, RIN 1545-BP04, Investing in Qualified Opportunity Funds. Opportunity Zones: No bill introduced but support legislative change to reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone substantial improvement purposes. H.R. 2593, to require the Secretary of the Treasury to collect data and issue a report on the opportunity zone tax incentives enacted by the 2017 tax reform legislation, and for other purposes, all provisions. H.R. 4011, to amend the Internal Revenue Code of 1986 to require lead remediation for qualified opportunity zone property originally constructed before January 1, 1978. H.R. 5011, Opportunity Zone Accountability and Transparency Act, to amend the Internal Revenue Code of 1986 to require reporting by qualified opportunity funds, all provisions. S. 1344, to require the Secretary of the Treasury to collect data and issue a report on the opportunity zone tax incentives enacted by the 2017 tax reform legislation, and for other purposes, all provisions. S. 2787, Opportunity Zone Reporting and Reform Act, to amend the Internal Revenue Code of 1986 to require reporting for qualified opportunity funds, to make modifications to opportunity zones, and for other purposes, all provisions. S. 2994, Improving and Reinstating the Monitoring, Prevention, Accountability, Certification, and Transparency Provisions of Opportunity Zones or the IMPACT Act, to amend the Internal Revenue Code of 1986 to require information reporting with respect to the qualified opportunity zone tax incentives enacted by the 2017 tax reform legislation, to require public reports related to such tax incentives, and for other purposes, all provisions. Low-Income Housing Tax Credit, Middle-Income Housing Tax Credit, and Incentives for Housing Affordability and Infrastructure Development H.R. 3077, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 1703, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 3365 (115th Congress), Middle-Income Housing Tax Credit Act of 2018, to provide a credit for middle-income housing, and for other purposes, all provisions. Requested that any infrastructure bill include tax incentives to: expand the Low-Income Housing Tax Credit; enact the Middle-Income Housing Tax Credit; reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes; repeal the Foreign Investment in Real Property Tax Act; extend the IRC Section 45L New Energy Efficient Home Credit; and extend and modify the IRC Section 179D Energy Efficient Commercial Buildings Deduction to facilitate investments in improving the utility performance of existing properties. Legislative proposal, to amend the Internal Revenue Code of 1986 to permit certain contributions by governmental entities to be treated as contributions of capital and to exclude from gross income contributions of capital of a partnership. Energy H.R. 1865, Further Consolidated Appropriations Act, 2020 (became Public Law 116-94), Division Q -- Revenue Provisions, Taxpayer Certainty and Disaster Relief Act of 2019, Section 129: Energy efficient homes credit and Section 131: Energy efficient commercial buildings deduction. H.R. 4506, Home Energy Savings Act, to amend the Internal Revenue Code of 1986 to extend and update the credit for nonbusiness energy property, all provisions. H.R. 4646, New Home Energy Efficiency Act, to amend the Internal Revenue Code of 1986 to extend and update the new energy efficient home credit, all provisions. S. 2588, Home Energy Savings Act, to amend the Internal Revenue Code of 1986 to extend and update the credit for nonbusiness energy property, all provisions. S. 2595, New Home Energy Efficiency Act, to amend the Internal Revenue Code of 1986 to extend and update the new energy efficient home credit, all provisions. Draft legislation, Growing Renewable Energy and Efficiency Now Act of 2019, or the GREEN Act of 2019, to amend the Internal Revenue Code to promote green energy, Section 303: Energy efficient commercial buildings deduction and Section 304: Extension, increase, and modifications of new energy efficient home credit. Draft legislation, Energy Efficient Qualified Improvement Property Act of 2019, or the E-QuIP Act, to amend the Internal Revenue Code to allow 10-year straight line depreciation for energy efficient qualified improvement property, and for other purposes, all provisions. Estate Tax Support making permanent the Estate Tax rules enacted as part of the Tax Cuts and Jobs Act of 2017. Tax Administration Letter to Treasury Department and IRS requesting a delay of the implementation of the 2019 Draft Form 1065 and Schedule K-1 by at least one year (until 2020) to allow for a full public review and comment process. Carried Interest H.R. 1735, Carried Interest Fairness Act of 2019, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-through entities, all provisions. S. 781, Carried Interest Fairness Act of 2019, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-through entities, all provisions. S. 1639, Ending the Carried Interest Loophole Act, to amend the Internal Revenue Code of 1986 to revise the treatment of partnership interests received in connection with the performance of services, and for other purposes, all provisions. Foreign Investment in Real Property Tax Act (FIRPTA) H.R. 2210, Invest in America Act, to amend the Internal Revenue Code of 1986 to repeal certain provisions applicable to foreign investment in United States real property, all provisions.

Depreciation Rules Requested Congress pass legislation or, alternatively, that the Treasury Department revisit Rev. Proc. 2019-08 and clarify through the regulatory process that firms electing out of limits on business interest deductibility may depreciate multifamily buildings placed in service prior to 2018 over 30 years. Business Interest Deductibility Department of Treasury and Internal Revenue Service, 26 CFR Part 1, REG-106089-18, RIN 1545-BO73, Limitation on Deduction for Business Interest Expense, issues pertaining to: (1) the interaction between the small business exception and the real estate trade or business election (as well as resulting impacts on the depreciation of multifamily buildings); and (2) the application of the REIT safe harbor to certain controlled partnerships. Opportunity Zones Department of the Treasury and Internal Revenue Service, 26 CFR Part 1, REG-120186-18, RIN 1545-BP04, Investing in Qualified Opportunity Funds. Opportunity Zones: No bill introduced but support legislative change to reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone substantial improvement purposes. S. 1344, to require the Secretary of the Treasury to collect data and issue a report on the opportunity zone tax incentives enacted by the 2017 tax reform legislation, and for other purposes, all provisions. H.R. 2593, to require the Secretary of the Treasury to collect data and issue a report on the opportunity zone tax incentives enacted by the 2017 tax reform legislation, and for other purposes, all provisions. H.R. 4011, to amend the Internal Revenue Code of 1986 to require lead remediation for qualified opportunity zone property originally constructed before January 1, 1978. Low-Income Housing Tax Credit, Middle-Income Housing Tax Credit, and Incentives for Housing Affordability and Infrastructure Development H.R. 3077, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 1703, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. H.R. 3479, Save Affordable Housing Act of 2019, to amend the Internal Revenue Code of 1986 to repeal the qualified contract exception to the extended low-income housing commitment rules for purposes of the low-income housing credit, and for other purposes, all provisions. S. 1956, Save Affordable Housing Act of 2019, to amend the Internal Revenue Code of 1986 to repeal the qualified contract exception to the extended low-income housing commitment rules for purposes of the low-income housing credit, and for other purposes, all provisions. S. 3365 (115th Congress), Middle-Income Housing Tax Credit Act of 2018, to provide a credit for middle-income housing, and for other purposes, all provisions. Legislative proposal, Renters Tax Credit Act of 2019, to amend the Internal Revenue Code of 1986 to provide a tax credit to taxpayers who provide reductions in rent to their tenants under State rental reduction programs, and for other purposes, all provisions. Requested that any infrastructure bill include tax incentives to: expand the Low-Income Housing Tax Credit; enact the Middle-Income Housing Tax Credit; reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes; repeal the Foreign Investment in Real Property Tax Act; extend the IRC Section 45L New Energy Efficient Home Credit; and extend and modify the IRC Section 179D Energy Efficient Commercial Buildings Deduction to facilitate investments in improving the utility performance of existing properties. Legislative proposal, to amend the Internal Revenue Code of 1986 to permit certain contributions by governmental entities to be treated as contributions of capital and to exclude from gross income contributions of capital of a partnership. Legislative proposal to spur housing development and infrastructure through: (1) tax-exempt bond financing in designated areas; and (2) increased community development block grant funding provided to States, local governments, and Indian tribes based on the extent to which those entities streamline development requirements for affordable housing, eliminate or reduce impact fees, and provide assurances they will supplement costs. Energy Support extending Energy efficient homes credit (IRC 45L) and Energy efficient commercial buildings deduction (IRC 179D). Also support modifying 179D to incentivize retrofits and allow REITs to benefit. H.R. 3301, The Taxpayer Certainty and Disaster Relief Act of 2019, to amend the Internal Revenue Code of 1986 to extend certain expiring provisions, to provide disaster relief, and for other purposes. Section 129: Energy efficient homes credit. Section 131: Energy efficient commercial buildings deduction. Section 201: Reduction of unified credit against estate tax. H.R. 4506, Home Energy Savings Act, to amend the Internal Revenue Code of 1986 to extend and update the credit for nonbusiness energy property, all provisions. S. 1288, Clean Energy for America Act, Title III -- Energy Efficiency Incentives: Section 301: Credit for new energy efficient residential buildings, Section 304: Deduction for new energy efficient commercial buildings, Section 305: Energy efficiency deduction for existing commercial buildings, and Section 306: Temporary extension of existing energy efficiency incentives. S. 2588, Home Energy Savings Act, to amend the Internal Revenue Code of 1986 to extend and update the credit for nonbusiness energy property, all provisions. Legislative tax proposal (Energy Efficient Qualified Improvement Property (E-QUIP)) to establish a 10-year depreciation period for high-performance energy-efficient qualified improvement property (i.e., heating, cooling, ventilation and hot water; lighting; and envelope) installed in a covered building, including a multifamily building. Legislative proposal, New Home Energy Efficiency Act, to amend the Internal Revenue Code of 1986 to extend and update the new energy efficient home credit, all provisions. Carried Interest H.R. 1735, Carried Interest Fairness Act of 2019, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-through entities, all provisions. H.R. 3848, Stop Wall Street Looting Act, to require the Securities and Exchange Commission to issue rules requiring private funds to publicly disclose certain information, and for other purposes: Title II -- Anti-Looting, Section 204, Limitation on deduction for business interest of certain businesses owned by private funds. Title IV -- Closing the Carried Interest Loophole, all provisions. S. 781, Carried Interest Fairness Act of 2019, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-through entities, all provisions. S. 1639, Ending the Carried Interest Loophole Act, to amend the Internal Revenue Code of 1986 to revise the treatment of partnership interests received in connection with the performance of services, and for other purposes, all provisions. S. 2155, Stop Wall Street Looting Act, to require the Securities and Exchange Commission to issue rules requiring private funds to publicly disclose certain information, and for other purposes: Title II -- Anti-Looting, Section 204, Limitation on deduction for business interest of certain businesses owned by private funds. Title IV -- Closing the Carried Interest Loophole, all provisions. Foreign Investment in Real Property Tax Act (FIRPTA) H.R. 2210, Invest in America Act, to amend the Internal Revenue Code of 1986 to repeal certain provisions applicable to foreign investment in United States real property, all provisions. Taxation of Capital Gains Monitored and analyzed proposal for Treasury Department to issue regulation that would index capital gains to inflation. Proposal by Senate Finance Committee Ranking Member Ron Wyden, Treat Wealth Like Wages, A plan to fix our broken tax code, ensure the wealthy pay their fair share, and protect Social Security.

Depreciation Rules Requested Congress pass legislation or, alternatively, that the Treasury Department revisit Rev. Proc. 2019-08 and clarify through the regulatory process that firms electing out of limits on business interest deductibility may depreciate multifamily buildings placed in service prior to 2018 over 30 years. Business Interest Deductibility Department of Treasury and Internal Revenue Service, 26 CFR Part 1, REG-106089-18, RIN 1545-BO73, Limitation on Deduction for Business Interest Expense, issues pertaining to: (1) the interaction between the small business exception and the real estate trade or business election (as well as resulting impacts on the depreciation of multifamily buildings); and (2) the application of the REIT safe harbor to certain controlled partnerships. Opportunity Zones Department of the Treasury and Internal Revenue Service, 26 CFR Part 1, REG-120186-18, RIN 1545-BP04, Investing in Qualified Opportunity Funds. Opportunity Zones: No bill introduced but support legislative change to reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone substantial improvement purposes. S. 1344, to require the Secretary of the Treasury to collect data and issue a report on the opportunity zone tax incentives enacted by the 2017 tax reform legislation, and for other purposes, all provisions. H.R. 2593, to require the Secretary of the Treasury to collect data and issue a report on the opportunity zone tax incentives enacted by the 2017 tax reform legislation, and for other purposes, all provisions. H.R. 4011, to amend the Internal Revenue Code of 1986 to require lead remediation for qualified opportunity zone property originally constructed before January 1, 1978. Low-Income Housing Tax Credit, Middle-Income Housing Tax Credit, and Incentives for Housing Affordability and Infrastructure Development H.R. 3077, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 1703, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. H.R. 3479, Save Affordable Housing Act of 2019, to amend the Internal Revenue Code of 1986 to repeal the qualified contract exception to the extended low-income housing commitment rules for purposes of the low-income housing credit, and for other purposes, all provisions. S. 1956, Save Affordable Housing Act of 2019, to amend the Internal Revenue Code of 1986 to repeal the qualified contract exception to the extended low-income housing commitment rules for purposes of the low-income housing credit, and for other purposes, all provisions. S. 3365 (115th Congress), Middle-Income Housing Tax Credit Act of 2018, to provide a credit for middle-income housing, and for other purposes, all provisions. Legislative proposal, Renters Tax Credit Act of 2019, to amend the Internal Revenue Code of 1986 to provide a tax credit to taxpayers who provide reductions in rent to their tenants under State rental reduction programs, and for other purposes, all provisions. Requested that any infrastructure bill include tax incentives to: expand the Low-Income Housing Tax Credit; enact the Middle-Income Housing Tax Credit; reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes; repeal the Foreign Investment in Real Property Tax Act; extend the IRC Section 45L New Energy Efficient Home Credit; and extend and modify the IRC Section 179D Energy Efficient Commercial Buildings Deduction to facilitate investments in improving the utility performance of existing properties. Legislative proposal, to amend the Internal Revenue Code of 1986 to permit certain contributions by governmental entities to be treated as contributions of capital and to exclude from gross income contributions of capital of a partnership. Legislative proposal to spur housing development and infrastructure through: (1) tax-exempt bond financing in designated areas; and (2) increased community development block grant funding provided to States, local governments, and Indian tribes based on the extent to which those entities streamline development requirements for affordable housing, eliminate or reduce impact fees, and provide assurances they will supplement costs. Energy Support extending Energy efficient homes credit (IRC 45L) and Energy efficient commercial buildings deduction (IRC 179D). Also support modifying 179D to incentivize retrofits and allow REITs to benefit. H.R. 3301, The Taxpayer Certainty and Disaster Relief Act of 2019, to amend the Internal Revenue Code of 1986 to extend certain expiring provisions, to provide disaster relief, and for other purposes. Section 129: Energy efficient homes credit. Section 131: Energy efficient commercial buildings deduction. Section 201: Reduction of unified credit against estate tax. H.R. 4506, Home Energy Savings Act, to amend the Internal Revenue Code of 1986 to extend and update the credit for nonbusiness energy property, all provisions. S. 1288, Clean Energy for America Act, Title III -- Energy Efficiency Incentives: Section 301: Credit for new energy efficient residential buildings, Section 304: Deduction for new energy efficient commercial buildings, Section 305: Energy efficiency deduction for existing commercial buildings, and Section 306: Temporary extension of existing energy efficiency incentives. S. 2588, Home Energy Savings Act, to amend the Internal Revenue Code of 1986 to extend and update the credit for nonbusiness energy property, all provisions. Legislative tax proposal (Energy Efficient Qualified Improvement Property (E-QUIP)) to establish a 10-year depreciation period for high-performance energy-efficient qualified improvement property (i.e., heating, cooling, ventilation and hot water; lighting; and envelope) installed in a covered building, including a multifamily building. Legislative proposal, New Home Energy Efficiency Act, to amend the Internal Revenue Code of 1986 to extend and update the new energy efficient home credit, all provisions. Carried Interest H.R. 1735, Carried Interest Fairness Act of 2019, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-through entities, all provisions. H.R. 3848, Stop Wall Street Looting Act, to require the Securities and Exchange Commission to issue rules requiring private funds to publicly disclose certain information, and for other purposes: Title II -- Anti-Looting, Section 204, Limitation on deduction for business interest of certain businesses owned by private funds. Title IV -- Closing the Carried Interest Loophole, all provisions. S. 781, Carried Interest Fairness Act of 2019, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-through entities, all provisions. S. 1639, Ending the Carried Interest Loophole Act, to amend the Internal Revenue Code of 1986 to revise the treatment of partnership interests received in connection with the performance of services, and for other purposes, all provisions. S. 2155, Stop Wall Street Looting Act, to require the Securities and Exchange Commission to issue rules requiring private funds to publicly disclose certain information, and for other purposes: Title II -- Anti-Looting, Section 204, Limitation on deduction for business interest of certain businesses owned by private funds. Title IV -- Closing the Carried Interest Loophole, all provisions. Foreign Investment in Real Property Tax Act (FIRPTA) H.R. 2210, Invest in America Act, to amend the Internal Revenue Code of 1986 to repeal certain provisions applicable to foreign investment in United States real property, all provisions. Taxation of Capital Gains Monitored and analyzed proposal for Treasury Department to issue regulation that would index capital gains to inflation. Proposal by Senate Finance Committee Ranking Member Ron Wyden, Treat Wealth Like Wages, A plan to fix our broken tax code, ensure the wealthy pay their fair share, and protect Social Security.

Depreciation Rules Requested Congress pass legislation or, alternatively, that the Treasury Department revisit Rev. Proc. 2019-08 and clarify through the regulatory process that firms electing out of limits on business interest deductibility may depreciate multifamily buildings placed in service prior to 2018 over 30 years. Business Interest Deductibility Department of Treasury and Internal Revenue Service, 26 CFR Part 1, REG-106089-18, RIN 1545-BO73, Limitation on Deduction for Business Interest Expense, issues pertaining to: (1) the interaction between the small business exception and the real estate trade or business election; and (2) the application of the REIT safe harbor to certain controlled partnerships. Section 199A Qualified Business Income Deduction H.R. 216, Main Street Tax Certainty Act, to amend the Internal Revenue Code of 1986 to make permanent the deduction for qualified business income, all provisions. S. 1149, Main Street Tax Certainty Act, to amend the Internal Revenue Code of 1986 to make permanent the deduction for qualified business income, all provisions. Opportunity Zones Department of Treasury and Internal Revenue Service, 26 CFR Part 1, REG-115420-18, RIN 1545-BP03, Investing in Qualified Opportunity Funds. Department of the Treasury and Internal Revenue Service, 26 CFR Part 1, REG-120186-18, RIN 1545-BP04, Investing in Qualified Opportunity Funds. Department of the Treasury, Request for Information on Data Collection and Tracking for Qualified Opportunity Zones. Department of Housing and Urban Development, Office of the Assistant Secretary for Policy Development and Research (PD&R), Request for Information, Docket No. FR-6155-N-01, Review of HUD Policy in Opportunity Zones. Opportunity Zones: No bill introduced but support legislative change to reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone substantial improvement purposes. S. 1344, to require the Secretary of the Treasury to collect data and issue a report on the opportunity zone tax incentives enacted by the 2017 tax reform legislation, and for other purposes, all provisions. H.R. 2593, to require the Secretary of the Treasury to collect data and issue a report on the opportunity zone tax incentives enacted by the 2017 tax reform legislation, and for other purposes, all provisions. Low-Income Housing Tax Credit, Middle-Income Housing Tax Credit, and Incentives for Housing Affordability H.R. 3077, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 1703, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. H.R. 3479, Save Affordable Housing Act of 2019, to amend the Internal Revenue Code of 1986 to repeal the qualified contract exception to the extended low-income housing commitment rules for purposes of the low-income housing credit, and for other purposes, all provisions. S. 1956, Save Affordable Housing Act of 2019, to amend the Internal Revenue Code of 1986 to repeal the qualified contract exception to the extended low-income housing commitment rules for purposes of the low-income housing credit, and for other purposes, all provisions. S. 3365 (115th Congress), Middle-Income Housing Tax Credit Act of 2018, to provide a credit for middle-income housing, and for other purposes, all provisions. S. 1106, Rent Relief Act, to amend the Internal Revenue Code of 1986 to allow for a credit against tax for rent paid on the personal residence of the taxpayer, all provisions. Requested that any infrastructure bill include tax incentives to: expand the Low-Income Housing Tax Credit; enact the Middle-Income Housing Tax Credit; reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes; repeal the Foreign Investment in Real Property Tax Act; extend the IRC Section 45L New Energy Efficient Home Credit; and extend and modify the IRC Section 179D Energy Efficient Commercial Buildings Deduction to facilitate investments in improving the utility performance of existing properties. Studied additional housing affordability legislative tax incentive proposals, including renters tax credit and tax-exempt bond financing for housing production within designated areas. Issues pertaining to LIHTC data collection. Energy Support extending Energy efficient homes credit (IRC 45L) and Energy efficient commercial buildings deduction (IRC 179D). Also support modifying 179D to incentivize retrofits and allow REITs to benefit. H.R. 3051, to amend the Internal Revenue Code of 1986 to extend by 2 years the energy efficient commercial buildings deduction, all provisions. H.R. 3301, The Taxpayer Certainty and Disaster Relief Act of 2019, to amend the Internal Revenue Code of 1986 to extend certain expiring provisions, to provide disaster relief, and for other purposes. Section 129: Energy efficient homes credit. Section 131: Energy efficient commercial buildings deduction. Section 201: Reduction of unified credit against estate tax. S. 617, Tax Extender and Disaster Relief Act of 2019, to amend the Internal Revenue Code of 1986 to extend certain expiring provisions, to provide disaster tax relief, and for other purposes. Section 110: Energy efficient homes credit. Section 113: Energy efficient commercial buildings deduction. S. 1288, Clean Energy for America Act, Title III -- Energy Efficiency Incentives: Section 301: Credit for new energy efficient residential buildings, Section 304: Deduction for new energy efficient commercial buildings, Section 305: Energy efficiency deduction for existing commercial buildings, and Section 306: Temporary extension of existing energy efficiency incentives Legislative tax proposal (Energy Efficient Qualified Improvement Property (E-QUIP)) to establish a 10-year depreciation period for high-performance energy-efficient qualified improvement property (i.e., heating, cooling, ventilation and hot water; lighting; and envelope) installed in a covered building, including a multifamily building. Carried Interest H.R. 1735, Carried Interest Fairness Act of 2019, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-through entities, all provisions. S. 781, Carried Interest Fairness Act of 2019, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-through entities, all provisions. S. 1639, Ending the Carried Interest Loophole Act, to amend the Internal Revenue Code of 1986 to revise the treatment of partnership interests received in connection with the performance of services, and for other purposes, all provisions. Foreign Investment in Real Property Tax Act (FIRPTA) H.R. 2210, Invest in America Act, to amend the Internal Revenue Code of 1986 to repeal certain provisions applicable to foreign investment in United States real property, all provisions.

Lobbied on the low income housing tax credit. No bill number. Lobbied on the middle income housing tax credit. S.3365 Middle-Income Housing Tax Credit Act of 2018.

Client expense: $440,000 · Firm income: Not reported

Government targets: Education, Dept of, Energy, Dept of, Environmental Protection Agency (EPA), Federal Emergency Management Agency (FEMA), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Natl Institute of Standards & Technology (NIST), Natl Park Service (NPS), SENATE, Treasury, Dept of

Depreciation Rules Requested Congress pass legislation or, alternatively, that the Treasury Department revisit Rev. Proc. 2019-08 and clarify through the regulatory process that firms electing out of limits on business interest deductibility may depreciate multifamily buildings placed in service prior to 2018 over 30 years Business Interest Deductibility Department of Treasury and Internal Revenue Service, 26 CFR Part 1, REG-106089-18, RIN 1545-BO73, Limitation on Deduction for Business Interest Expense, issues pertaining to: (1) the interaction between the small business exception and the real estate trade or business election; and (2) the application of the REIT safe harbor to certain controlled partnerships. Section 199A Qualified Business Income Deduction Tax Technical and Clerical Corrections Act (published as discussion draft on January 2, 2019), Section 4: Amendments Related to Public Law 115-97, provision clarifying that REIT dividends attributable to mutual funds qualifies for Qualified Business Income Deduction. H.R. 216, Main Street Tax Certainty Act, to amend the Internal Revenue Code of 1986 to make permanent the deduction for qualified business income, all provisions. Department of Treasury and Internal Revenue Service, 26 CFR Part 1, TD 9847, RIN 1545-BO71, Final Regulations, Qualified Business Income Deduction Department of Treasury and Internal Revenue Service, 26 CFR Part 1, REG-107892-18, RIN 1545-BO71, Proposed Regulations, Qualified Business Income Deduction Opportunity Zones Department of Treasury and Internal Revenue Service, 26 CFR Part 1, REG-115420-18, RIN 1545-BP03, Investing in Qualified Opportunity Funds Opportunity Zones: No bill introduced but support legislative change to reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes. Low-Income Housing Tax Credit, Middle-Income Housing Tax Credit, and Incentives for Housing Affordability Support making permanent the 12.5 percent increase in LIHTC authority enacted in March 2018 for 2018-2021 and further augmenting credit authority by 50 percent. Also support establishing a minimum 4 percent LIHTC tax credit rate Draft Legislation, Affordable Housing Credit Improvement Act of 2019, to amend the Internal Revenue Code of 1986 to reform the low-income housing tax credit, and for other purposes, all provisions with a specific focus on those expanding LIHTC allocations; establishing a minimum 4 percent credit; and impacting domestic violence, Qualified Contracts, and Right of First Refusal. Potential Draft legislation for S. 548 (115th Congress), Affordable Housing Credit Improvement Act of 2017, to amend the Internal Revenue Code of 1986 to reform the low-income housing tax credit, and for other purposes, all provisions. Potential Draft legislation for S. 3365 (115th Congress), Middle-Income Housing Tax Credit Act of 2018, to provide a credit for middle-income housing, and for other purposes, all provisions. Also engaged in discussions about feasibility of expanding proposal to enable use of tax-exempt bonds. S. 787, American Housing and Economic Mobility Act of 2019, to make housing more affordable and for other purposes, all provisions. Potential Draft legislation for S. 3250 (115th Congress), Rent Relief Act, to amend the Internal Revenue Code of 1986 to allow for a credit against tax for rent paid on the personal residence of the taxpayer, all provisions. Potential Draft legislation for S. 3342 (115th Congress), Housing, Opportunity, Mobility, and Equity Act of 2018, to require Community Development Block Grant recipients to develop a strategy to support inclusive zoning policies, to allow for a credit to support housing affordability, and for other purposes, all provisions. Requested that any infrastructure bill include tax incentives to expand the Low-Income Housing Tax Credit, enact the Middle-Income Housing Tax Credit, reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes, and repeal or further reform the Foreign Investment in Real Property Tax Act. Studied additional housing affordability legislative tax incentive proposals, including 80/20 bonds and establishing Qualified Equitable Housing Zones Energy Support extending Energy efficient homes credit (IRC 45L) and Energy efficient commercial buildings deduction (IRC 179D) S. 617, Tax Extender and Disaster Relief Act of 2019, to amend the Internal Revenue Code of 1986 to extend certain expiring provisions, to provide disaster tax relief, and for other purposes. Section 110: Energy efficient homes credit. Section 113: Energy efficient commercial buildings deduction. Legislative tax proposal to establish a 10-year depreciation period for high-performance energy-efficient qualified improvement property (i.e., heating, cooling, ventilation and water temperature; lighting; and envelope) installed in a covered building, including a multifamily building. Carried Interest H.R. 1735, Carried Interest Fairness Act of 2019, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-through entities, all provisions. S. 781, Carried Interest Fairness Act of 2019, to amend the Internal Revenue Code of 1986 to provide for the proper tax treatment of personal service income earned in pass-through entities, all provisions. Like-Kind Exchanges Support like-kind exchanges for real estate as maintained in Tax Cuts and Jobs Act (Public Law 115-97) Foreign Investment in Real Property Tax Act (FIRPTA) We support repeal or further reforms to promote foreign investment in the U.S. multifamily industry. Draft legislation (became H.R. 2210 that was introduced on April 10, 2019), Invest in America Act, to amend the Internal Revenue Code of 1986 to repeal certain provisions applicable to foreign investment in United States real property, all provisions. H.R. 6726 (115th Congress), Invest in America Act, to amend the Internal Revenue Code of 1986 to repeal certain provisions applicable to foreign investment in United States real property, all provisions.

Lobbied on the low income housing tax credit. No bill number. Lobbied on the middle income housing tax credit. S.3365 Middle-Income Housing Tax Credit Act of 2018.

Client expense: $420,000 · Firm income: Not reported

Government targets: Education, Dept of, Energy, Dept of, Environmental Protection Agency (EPA), Federal Emergency Management Agency (FEMA), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Natl Institute of Standards & Technology (NIST), Natl Park Service (NPS), SENATE, Treasury, Dept of

Lobbied on the low income housing tax credit. No bill number. Lobbied on the middle income housing tax credit. S.3365 Middle-Income Housing Tax Credit Act of 2018.

Client expense: $390,000 · Firm income: Not reported

Government targets: Education, Dept of, Energy, Dept of, Environmental Protection Agency (EPA), Federal Emergency Management Agency (FEMA), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Natl Institute of Standards & Technology (NIST), Natl Park Service (NPS), SENATE, Treasury, Dept of

Lobbied on Section 179D, the Energy Efficient Commercial Building Tax Deduction. No bill number. Lobbied on full repeal of the Foreign Investment in Real Property Tax Act. H.R. 6726 Invest in America Act. Lobbied on the low income housing tax credit. No bill number. Lobbied on the middle income housing tax credit. S.3365 Middle-Income Housing Tax Credit Act of 2018. Researched the qualified improvement property of the TaxCuts and Jobs Act of 2017, H.R.1, and potential expansion to include energy efficiency qualified improvement property.

Client expense: $390,000 · Firm income: Not reported

Government targets: Education, Dept of, Energy, Dept of, Environmental Protection Agency (EPA), Federal Emergency Management Agency (FEMA), General Services Administration (GSA), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Natl Institute of Standards & Technology (NIST), Natl Park Service (NPS), SENATE, Treasury, Dept of

Tax Reform Implementation, Technical Corrections, and Extension of Expiring Provisions Implementation of Tax Cuts and Jobs Act (2017 Tax Reform Act, Public Law 115-97) with respect to Deduction for Qualified Business Income of Pass-Thru Entities, Applicable Recovery Period for Real Property, Limitation on Deduction for Interest, Like-Kind Exchanges of Real Property, and Opportunity Zones. Asked Congress to enact technical correction or Treasury / Internal Revenue Service to issue guidance clarifying a 30-year depreciation period applies to multifamily properties placed in service prior to 2018 owned by firms electing out of interest deductibility limits. H.R. 88, House Amendment to H.R. 88, Retirement, Savings, and Other Tax Relief Act 2018 and the Taxpayer First Act of 2018. Division A -- Retirement, Savings, and Other Tax Relief Act of 2018: Title V: Certain Tax Technical Corrections and Clarifications: Section 501(a). Amendments Relating to Section 11011 (clarifies treatment of REIT dividends held by mutual funds for purposes of 20 percent qualified income deduction), Section 502: Clarification of Treatment of Veterans as Specified Group for Purposes of Low-Income Housing Tax Credit, Section 503: Clarification of General Public Use Requirement for Qualified Residential Rental Projects. House Rules Committee Print 115-85, House Amendment to H.R. 88, Retirement, Savings, and Other Tax Relief Act 2018 and the Taxpayer First Act of 2018. Division A -- Retirement, Savings, and Other Tax Relief Act of 2018: Title I: Extension of Expiring Provisions, Subtitle C -- Extensions for 2018: Section 128: Energy Efficient Homes Credit and Section 131: Energy Efficient Commercial Buildings Deduction. Title V: Certain Tax Technical Corrections and Clarifications: Section 501(a). Amendments Relating to Section 11011 (clarifies treatment of REIT dividends held by mutual funds for purposes of 20 percent qualified income deduction), Section 502: Clarification of Treatment of Veterans as Specified Group for Purposes of Low-Income Housing Tax Credit, Section 503: Clarification of General Public Use Requirement for Qualified Residential Rental Projects. Also asked Congress to include a technical correction clarifying a 30-year depreciation period applies to multifamily properties placed in service prior to 2018 owned by firms electing out of interest deductibility limits. House Rules Committee Print 115-86, House Amendment to H.R. 88, Retirement, Savings, and Other Tax Relief Act 2018 and the Taxpayer First Act of 2018. Division A -- Retirement, Savings, and Other Tax Relief Act of 2018: Title IV: Certain Tax Technical Corrections and Clarifications: Section 401(a). Amendments Relating to Section 11011 (clarifies treatment of REIT dividends held by mutual funds for purposes of 20 percent qualified income deduction), Section 402: Clarification of Treatment of Veterans as Specified Group for Purposes of Low-Income Housing Tax Credit, Section 403: Clarification of General Public Use Requirement for Qualified Residential Rental Projects. Also asked Congress to include a technical correction clarifying a 30-year depreciation period applies to multifamily properties placed in service prior to 2018 owned by firms electing out of interest deductibility limits. Supported extension of Credit for Energy-Efficient New Homes (IRC Section 45L). We also favored extending and improving the Energy Efficient Commercial Buildings Deduction (IRC Section 179D) by establishing a sliding scale of energy improvements, which would help spur investment in energy efficient improvements in older buildings. Department of Treasury and Internal Revenue Service, 26 CFR Part 1, REG-107892-18, RIN 1545-BO71, Qualified Business Income Deduction. Department of Treasury and Internal Revenue Service, 26 CFR Part 1, REG-115240-18, RIN 1545-BP03, Investing in Qualified Opportunity Funds. Opportunity Zones: No bill introduced, but we support a legislative change to reduce the basis increase necessary to qualify a multifamily rehabilitation project for Opportunity Zone purposes. Department of Treasury and Internal Revenue Service, 26 CFR Part 1, REG-106089-18, RIN 1545-BO73, Limitation on Deduction for Business Interest Expense. Low-Income Housing Tax Credit, Middle-Income Housing Tax Credit, and Housing Production Tax Incentives H.R. 1661, Affordable Housing Credit Improvement Act of 2017, to amend the Internal Revenue Code of 1986 to reform the low-income housing tax credit, and for other purposes, all provisions. S. 548, Affordable Housing Credit Improvement Act, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. S. 3365, Middle-Income Housing Tax Credit Act of 2018, to provide a credit for middle-income housing, and for other purposes, all provisions. H.R., 3670, to amend the Internal Revenue Code of 1986 to allow for a credit against tax for rent paid on the personal residence of the taxpayer, all provisions. S. 3250, Rent Relief Act, to amend the Internal Revenue Code of 1986 to allow for a credit against tax for rent paid on the personal residence of the taxpayer, all provisions. Discussions with Congressional staff regarding expanding LIHTC to serve extremely low-income households. No specific bill, but studied legislative proposals regarding Qualified Contracts under Low-Income Housing Tax Credit FIRPTA H.R. 6726, Invest in America Act, to amend the Internal Revenue Code of 1986 to repeal certain provisions applicable to foreign investment in United States real property, all provisions.

All Policies related to Tax Reform; all provisions related to the Low Income Housing Tax Credit, Opportunity Zones, and the UBIT Fringe Benefits Tax. All policies relating to the Low Income Housing Tax Credit. Public Law No: 115-141 (H.R. 1652): Consolidated Appropriations Act, 2018 This is a large omnibus bill providing appropriations for the remainder of FY 2018 for all federal departments. Two key LIHTC provisions were included in the bill: 12.5% credit allocation expansion for four years, and a permanent authorization of the income-averaging option. Signed by the President on March 23, 2018. Public Law No. 115-97 (H.R. 1): Tax Cuts and Jobs Act: This bill amends the Internal Revenue Code to reduce tax rates and modify policies, credits, and deductions for individuals and businesses. It preserves the Low-Income Housing Tax Credit program, with no modifications, and retains the tax-preferred status on Multifamily Housing Bonds. The legislation lowers the top corporate tax rate from 35% to 21%, effective January 1, 2018, which will likely affect Housing Credit pricing and value. The law also creates a base erosions and anti-abuse tax (BEAT), which would make Housing Credit investment less attractive to certain investors with foreign operations. However, the final bill exempts 80% of the value of the Housing Credit from the BEAT, which could mitigate the impact. Signed by the President on December 22, 2017. S. 548 / H.R. 1661: The Affordable Housing Credit Improvement Act. This bill seeks to expand the LIHTC and includes additional provisions to make the program more streamlined and flexible. The Housing Credit allocation authority would be expanded by 50%, which is expected to finance the development or preservation of up to 400,000 additional affordable units over the next decade (the expansion provision is excluded from the House version of the bill). The bill would also: provide a minimum 4% Housing Credit rate for the acquisition of affordable housing and for multifamily Housing Bond-financed developments; permit income averaging in Housing Credit properties to preserve rigorous targeting while providing more flexibility and responsiveness to local needs; create incentives for projects that target homeless or extremely low-income individuals and families, as well as in Native American communities; allow 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; align LIHTC rules, such as the student rule, more closely with HUD regulations; rename the LIHTC to the Affordable Housing Tax Credit (AHTC); all provisions S. 293 / H.R. 828: Investing in Opportunity Act. This bill aims to improve the economy of distressed areas through a capital gains tax deferment, reduction, or exemption in exchange for reinvestment in Opportunity Zones - geographically targeted low-income areas that would be designated by state governors. The capital gains from the sale or exchange any asset held by the taxpayer would be pooled into newly-created Opportunity Funds, which would be established specifically for making investments in distressed communities; all provisions. H.R. 948: Common Sense Housing Investment Act. This bill would amend the Internal Revenue Code of 1986 to replace the mortgage interest deduction (MID) with a nonrefundable 15% tax credit on the mortgage interest of a primary and secondary residence, up to $500,000. The adjustment is expected to affect only 6% of mortgage holders currently benefitting from the MID, while the replacement would expand the mortgage interest tax benefits to more moderate and low-income homeowners. The savings, which could total $241 billion over 10 years, would be reinvested in affordable housing programs, including the LIHTC and the Housing Trust Fund; all provisions. H.R.6671/S.3250 - Rent Relief Act of 2018 - This bill amends the Internal Revenue Code to allow a refundable tax credit for individuals who pay rent for a principal residence that exceeds 30% of the individual's gross income for the taxable year. The amount of the credit ranges from 25% to 100% of the excess rent, depending on the gross income of the taxpayer. The credit is not available for taxpayers with gross income that exceeds $100,000 ($125,000 for a taxpayer whose principal residence is located in a high-cost area, as defined by the bill). Rent that exceeds 150% of the fair market rent (including the utility allowance) for the residence may not be taken into account for the purpose of determining the amount of the credit. For individuals who reside in government-subsidized housing, the bill allows a credit equal to 1/12 of the rent paid by the taxpayer (and not subsidized under the program) during the year with respect to the residence. S.3365 - Middle-Income Housing Tax Credit Act of 2018 - This bill amends the Internal Revenue Code to allow a tax credit for the development of housing for middle-income households. The credit is based on the existing low-income housing tax credit and applies to the development or rehabilitation of residential rental properties if: (1) 60% or more of the residential units in the project are both rent-restricted and occupied by individuals whose income is 100% or less of the area median gross income, and (2) the project is not federally subsidized or financed with a federally funded grant. The credits are allocated to each state based on population, and state housing agencies then distribute the credits to developers using a competitive process. The credits are paid over a 15-year credit period, and the amounts of the credits are based on a percentage of a project's qualified basis, which is the portion of the project dedicated to affordable middle-income housing. The credit dollar amount allocated to a project may not exceed the amount that is necessary for the financial feasibility of the project and its viability as a qualified middle-income housing project throughout the credit period. To qualify for the credit, the developer must make a long-term commitment to middle-income housing, under which the affordability restrictions for a property remain in place for at least an additional 15 years after the close of the credit period. S. 434 / H.R. 1145: Housing for Homeless Students Act This bill amends the IRS housing credit guidelines to qualify low-income building units that provide housing for homeless children, youth, and veterans who are full-time students. In order to become eligible for the LIHTC, the building units student residents must have been homeless during any portion of the preceding five years (for veterans) or seven years (for children and youth).

Lobbied on Section 179D, the Energy Efficient Commercial Building Tax Deduction. No bill number. Lobbied on full repeal of the Foreign Investment in Real Property Tax Act. H.R. 6726 Invest in America Act. Lobbied on the low income housing tax credit. No bill number. Lobbied on the middle income housing tax credit. S.3365 Middle-Income Housing Tax Credit Act of 2018. Researched the qualified improvement property of the TaxCuts and Jobs Act of 2017, H.R.1, and potential expansion to include energy efficiency qualified improvement property.

Client expense: $390,000 · Firm income: Not reported

Government targets: Education, Dept of, Energy, Dept of, Environmental Protection Agency (EPA), Federal Aviation Administration (FAA), Federal Emergency Management Agency (FEMA), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), SENATE, Treasury, Dept of

Lobbied on the low income housing tax credit. No bill number. Lobbied on the middle income housing tax credit. S.3365 Middle-Income Housing Tax Credit Act of 2018.

Client expense: $390,000 · Firm income: Not reported

Government targets: Education, Dept of, Energy, Dept of, Environmental Protection Agency (EPA), Federal Aviation Administration (FAA), Federal Emergency Management Agency (FEMA), Federal Trade Commission (FTC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), SENATE, Treasury, Dept of

Tax Reform Implementation and Extension Implementation of Public Law 115-97 (2017 Tax Reform Act) with respect to: Subtitle A -- Individual Tax Reform, Part II Deduction for Qualified Business Income of Pass-Thru Entities: Section 11011: Deduction for Qualified Business Income. Subtitle C -- Business-Related Provisions: Part III -- Cost Recovery and Accounting Methods: Section 13201: Temporary 100 Percent Expensing for Certain Business Assets, Section 13204: Applicable Recovery Period for Real Property. Part IV -- Business-Related Exclusions and Deductions: Section 13301: Limitation on Deduction for Interest, Section 13303: Like-Kind Exchanges of Real Property, Section 13309: Recharacterization of Certain Gains in the Case of Partnership Profits Interests Held in Connection with Performance of Investment Services. Section 13312: Certain Contributions by Governmental Entities not Treated as Contributions to Capital. Part IX -- Other Provisions: Section 13823: Opportunity Zones H.R. 6760, Protecting Family and Small Business Tax Cuts Act of 2018, to amend the Internal Revenue Code of 1986 to make permanent certain provisions of the Tax Cuts and Jobs Act affecting individuals, families, and small businesses, Section 101: Modification of rates, Section 111: Deduction for qualified business income, Section 112: Limitation of losses for taxpayers other than corporations, and Section 151: Increase in estate and gift tax exemption. Energy Tax Incentives No specific bill, but support extending Credit for Energy-Efficient New Homes (IRC Section 45L) and the Energy Efficient Commercial Buildings Deduction (IRC Section 179D). We also considered proposals to incentivize faster depreciation of energy efficiency improvements. Low-Income Housing Tax Credit, Middle-Income Housing Tax Credit, Housing Production Tax Incentives, and Rental Tax Credits H.R. 1661, Affordable Housing Credit Improvement Act of 2017, to amend the Internal Revenue Code of 1986 to reform the low-income housing tax credit, and for other purposes, all provisions. S. 548, Affordable Housing Credit Improvement Act, to amend the Internal Revenue Code of 1986 to reform the low-income housing credit, and for other purposes, all provisions. No specific bill, but studied legislative proposals regarding Qualified Contracts under Low-Income Housing Tax Credit. S. 3365, Middle-Income Housing Tax Credit Act of 2018, to provide a credit for middle-income housing, and for other purposes, all provisions. Studied 80/20 Tax-Exempt Qualified Family Communities Bond Program, a proposal to create affordable housing near transit H.R., 3670, to amend the Internal Revenue Code of 1986 to allow for a credit against tax for rent paid on the personal residence of the taxpayer, all provisions. S. 3250, Rent Relief Act, to amend the Internal Revenue Code of 1986 to allow for a credit against tax for rent paid on the personal residence of the taxpayer, all provisions. S. 3342, Housing, Opportunity, Mobility, and Equity Act of 2018, to require Community Development Block Grant recipients to develop a strategy to support inclusive zoning policies, to allow for a credit to support housing affordability, and for other purposes, all provisions. FIRPTA H.R. 6726, Invest in America Act, to amend the Internal Revenue Code of 1986 to repeal certain provisions applicable to foreign investment in United States real property, all provisions. Treasury Regulations Department of Treasury and Internal Revenue Service, 26 CFR Part 1, REG-107892-18, RIN 1545-BO71, Qualified Business Income Deduction Department of Treasury and Internal Revenue Service, 26 CFR Part 1, REG-104397-18, RIN 1545-BO74, Additional First-Year Depreciation Deduction