DEBRIS Act of 2023

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

Client expense: $1,820,000 · Firm income: Not reported

Government targets: Council of Economic Advisers (CEA), Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Housing Finance Agency (FHFA), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Housing & Urban Development, Dept of (HUD), Labor, Dept of (DOL), Natl Economic Council (NEC), Office of Management & Budget (OMB), President of the U.S., SENATE, Securities & Exchange Commission (SEC), Vice President of the U.S.

*Public Law No: 115-334. All provisions related to the domestic sugar program and any legislation affecting current law. *Administration and management of U.S. sugar policy. *HR 2617, Consolidated Appropriations Act, 2023, agriculture disaster assistance implementation *S. 587/H.R. 1301, Death Tax Repeal Act *HR 1604/S. 754, Farm and Food Cybersecurity Act *H.R.8467, Farm, Food, and National Security Act of 2024, provisions relating to sugar *The Rural Prosperity and Food Security Act of 2024 (Senate Democratic Framework, unnumbered, not yet introduced), provisions relating to sugar *Senate Republican Framework for 2024 Farm Bill (unnumbered, not yet introduced), provisions relating to sugar *HR 10545, American Relief Act, 2025, provisions relating to sugar and agriculture disaster aid *PN11-12, Ms. Brooke Rollins nomination as Secretary of Agriculture *Tax provisions relating to agriculture in reauthorization of Tax Cuts and Jobs Act, P.L. 115-97, including section 199A *Federal Insecticide, Fungicide, and Rodenticide Act, 7 U.S.C. 136, relating to ongoing implementation *FY2026 Agriculture Appropriations Bill, not yet numbered or introduced, regarding crop insurance *FY2026 Budget Resolution, not yet numbered or introduced, regarding crop insurance *PN12-43, Mr. Stephen Vaden nomination as Deputy Secretary of Agriculture *PN13-5, Mr. Richard Fordyce nomination as Undersecretary for FPAC *PN12-26, Mr. Luke Lindberg nomination as Undersecretary for Trade

Client expense: $660,000 · Firm income: Not reported