Policy Regulations:
Advocacy
Comment Letters
Allocation Agreement
Working Group Comments Regarding the NMTC Allocation Agreement (August 30, 2007)
Novogradac & Company LLP Letter to Matt Josephs/CDFI Fund Regarding the NMTC Draft Allocation Agreement (August 28, 2006)
Novogradac & Company LLP Letter to Matt Josephs/CDFI Fund Regarding the NMTC Allocation Agreement Q&A (July 31, 2006)
Novogradac Company LLP Letter to Matt Josephs/CDFI Fund Regarding the 2005 Allocation Agreement (August 22, 2005)
Industry Comments to the CDFI Fund on the Draft New Markets Tax Credit Program Allocation Agreement (March 10, 2003)
Allocation Application
Working Group Letter to CDFI Fund with Supplemental Comments on Targeted Populations and the 2009 NMTC Allocation Application (November 23, 2009)
NH&RA Letter to Matt Josephs/CDFI Fund Regarding Related Party Equity Investments (October 2, 2009)
Working Group Letter to Matt Josephs at CDFI Fund Regarding the Final 2009 Allocation Application (October 12, 2009)
American Bankers Association Letter to CDFI Fund Regarding the Final 2009 Allocation Application (October 2, 2009)
Ariel Ventures, LLC Letter to CDFI Fund Regarding the Final 2009 Allocation Application (October 2, 2009)
Bank of America Merrill Lynch Letter to CDFI Fund Regarding the Final 2009 Allocation Application (October 2, 2009)
Clearinghouse CDFI Fund Letter to CDFI Fund Regarding the Final 2009 Allocation Application (October 2, 2009)
Coastal Enterprise, Inc. Capital Management Letter to CDFI Fund Regarding the Final 2009 Allocation Application (October 2, 2009)
Community Reinvestment Fund, USA Letter to CDFI Fund Regarding the Final 2009 Allocation Application (October 2, 2009)
David J. McGrady Letter to CDFI Fund Regarding the Final 2009 Allocation Application (September 3, 2009)
Dean Albert Cantalupo Letter to CDFI Fund Regarding the Final 2009 Allocation Application (September 19, 2009)
Enterprise Letter to CDFI Fund Regarding the Final 2009 Allocation Application (October 2, 2009)
First Southern Capital Development Letter to CDFI Fund Regarding the Final 2009 Allocation Application (September 25, 2009)
IFF Letter to CDFI Fund Regarding the Final 2009 Allocation Application (October 2, 2009)
Massachusetts Housing Investment Corporation Letter to CDFI Fund Regarding the Final 2009 Allocation Application (October 2, 2009)
Nancy Grandquist Letter to CDFI Fund Regarding the Final 2009 Allocation Application (October 7, 2009)
National Trust Community Investment Corp Letter to CDFI Fund Regarding the Final 2009 Allocation Application (September 29, 2009)
Opportunity Finance Network Letter to CDFI Fund Regarding the Final 2009 Allocation Application (October 2, 2009)
Strategic Development Group Letter to CDFI Fund Regarding the Final 2009 Allocation Application (October 5, 2009)
U.S. Green Building Council Letter to CDFI Fund Regarding the Final 2009 Allocation Application (October 2, 2009)
Woodstock Institute Letter to CDFI Fund Regarding the Final 2009 Allocation Application (October 1, 2009)
New Markets Tax Credit Coalition Letter to CDFI Fund Director Donna Gambrell Regarding the NMTC Allocation Application (July 24, 2008)
Working Group Letter to Matt Josephs at CDFI Fund Regarding the 2008 NMTC Allocation Application (February 8, 2008)
Working Group Comments Regarding the 2007 NMTC Allocation Application (August 30, 2007)
2007 NMTC Allocation Application with Comments (August 30, 2007)
Working Group Comments Regarding the Draft 2007 NMTC Program Allocation Application (November 14, 2006)
Novogradac Company LLP et al Additional Comment Letter concerning the New Markets Tax Credit (NMTC) Program Allocation Application (March 15, 2006)
Novogradac Company LLP et al Comment Letter concerning the New Markets Tax Credit (NMTC) Program Allocation Application (February 27, 2006)
Alternative Minimum Tax (AMT)
NMTC Coalition H.R. 4849 Comment Letter (March 16, 2010)
Community Investment Impact System (CIIS)
NMTC Working Group Letter Regarding the Community Investment Impact System (CIIS) (January 3, 2008)
Compliance and Monitoring FAQ
NMTC Working Group Comment Letter on Updated Compliance and Monitoring FAQ (August 11, 2009)
NMTC Working Group Letter Regarding Comments & Recommendations on Compliance & Monitoring FAQ Dated November 2006 (June 18, 2007)
Community Reinvestment Act (CRA)
Novogradac Company LLP Comment Letter Regarding CRA NMTC Regulations (October 16, 2001)
Definition of Control
NMTC Working Group Letter Regarding the Definition of Control as it Relates to the Reasonable Expectations Test (August 20, 2010)
Economic Substance Doctrine
NMTC Working Group Letter Requesting Guidance on Codification of the Economic Substance Doctrine (July 28, 2010)
NMTC Coalition Letter to Acting Assistant Secretary for Tax Policy Michael Mundaca Regarding the Codification of the Economic Substance Doctrine and the NMTC (January 15, 2010)
Economic Stimulus
New Markets Tax Credit Coalition Proposal: New Markets Tax Credits and Economic Recovery Legislation (October 27, 2008)
GAO Reports
Letter from CDFI Fund Director Gambrell to GAO About Minority Entities' Participation in NMTC Program (April 23, 2009)
Guidance Priority List
NMTC Working Group Letter Regarding Notice 2009-43 Public Comment Invited on Recommendations for 2009-2010 Guidance Priority List (May 31, 2009)
NMTC Working Group Letter Regarding Notice 2008-47 Public Comment Invited on Recommendations for 2008-2009 Guidance Priority List (May 30, 2008)
NMTC Working Group Letter Regarding Notice 2007-41 Public Comment Invited on Recommendations for 2007-2008 Guidance Priority List (May 31, 2007)
Loss of Basis
NMTC Working Group Letter: QLICI - Loss of Basis Issue (May 18, 2010)
Miscellaneous and Assorted Topics
NMTC Working Group Letter to Sens. Baucus and Grassley Seeking Clarification of the Integrated Unit Test (April 24, 2009)
Rep. Bob Filner Letter to Treasury Secretary Henry M. Paulson, Jr.Regarding Census Tract Issue in San Diego (November 9, 2007)
Ernst & Young Letter to Eric Solomon/IRS Regarding New Markets Tax Credit Investments and Profit Motivation (October 2, 2006)
Senate Letter of Support for $80 Million Fiscal Year 2006 Budget for CDFI Fund (April 27, 2005)
Letter to Eric Solomon, Acting Assistant Secretary of the Treasury, and Paul F. Handleman, IRS Office of the Associate Chief Counsel, Regarding Final Regulations (January 6, 2005)
Letter to Eric Solomon, Treasury Deputy Assistant Secretary for Tax Policy, Regarding Priority Items in NMTC Regulations
New Markets Tax Credit Coalition (October 18, 2004)
Novogradac Company LLP Comment Letter on Revised Temporary NMTC Regulations
Novogradac Company LLP (May 10, 2004)
NMTC Coalition Comment Letter on Revised Temporary NMTC Regulations
New Markets Tax Credit Coalition (May 10, 2004)
Letter to Eric Solomon, Treasury Deputy Assistant Secretary for Tax Policy, Regarding the NMTC Program
From the New Markets Tax Credit Coalition (June 20, 2003)
Letter to Eric Solomon, Treasury Deputy Assistant Secretary for Tax Policy, Regarding Unresolved NMTC Issues
From Michael J. Novogradac, CPA and Thomas Tracy, Esq. (May 09, 2003)
Letter to Eric Solomon, Treasury Deputy Assistant Secretary for Tax Policy, Regarding Unresolved NMTC Issues
From the New Markets Tax Credit Coalition (May 16, 2003)
General Accounting Office Letter to Congress: "New Markets Tax Credit: Status of Implementation and Issues Related to GAO’s Mandated Reports" (December 6, 2002)
New Markets Tax Credit Coalition Letter to President Bush Requesting Additional Allocation of NMTCs Be Included in Economic Stimulus Package (December 13, 2002)
New Markets Tax Credit Coalition Letter To the Treasury Dept. Requesting Guidance on NMTC Temporary Regulations (T.D. 8971) (August 8, 2002)
New Markets Tax Credit Coalition Letter To the Treasury Dept. Requesting Guidance on NMTC Temporary Regulations (T.D. 8971) (June 11, 2002)
Comments Received by the IRS on NMTC Regulations (August 21, 2001)
IRS Comment Letters on NMTC Regulations (February 25, 2002)
Industry Comments Received on the CDFI Fund's New Markets Tax Credits Guidance Published in the Federal Register May 1, 2001 (Summer 2001)
NMTC Extension
NMTC Coalition Letter to Congress in Support of the New Markets Tax Credit Extension Act of 2009 (October 2009)
NMTC Coalition Letter to Assistant Secretary for Tax Policy Eric Solomon Urging Extension of the NMTC as Part of an Economic Stimulus Package (January 8, 2008)
Multiple Senators Letter to Senate Finance Committee Chairman Baucus (D-MT) and Ranking Member Grassley (R-IA) in Support of Long Term NMTC Extension (October 17, 2007) {list of Senators who signed}
Letter to Urge Support for NMTC Extension in the House of Representatives from Representatives Richard Neal (D-MA) and Ron Lewis (R-KY)
(May 17, 2007)
Letter to Urge Support for NMTC Extension in the Senate from Senators John Rockefeller (D-WV) and Olympia Snowe (R-ME)
(May 17, 2007)
Art Garcia Letter to Alliance for Economic Development in Response to Inquiry Regarding Extension of the NMTC Program (November 21, 2006)
Alliance for Economic Development Letter to Treasury Secretary Paulson Encouraging Extension for the NMTC Program (October 31, 2006)
Art Garcia Letter to NMTC Coalition in Response to Inquiry Regarding Extension of the NMTC Program (October 24, 2006)
NMTC Coalition Letter to Treasury Secretary Paulson Calling for Five-Year Extension of the NMTC Program (October 12, 2006)
NMTC Coalition Letter to Tax Reconciliation Conference Committee Urging the Extension of the New Markets Tax Credit (January 31, 2006)
Eric Solomon Letter to Robert Rapoza/NMTC Coalition Regarding Administration Support for Reauthorization of the NMTC Program (November 2, 2005)
Non-Metro QEI Allocations
The following letters were submitted to the CDFI Fund in response to an invitation to comment regarding non-metro QEI Allocations
Advantage Capital Partners (July 5, 2007)
Alliance for Economic Development (July 5, 2007)
Appalachian Regional Commission (June 29, 2007)
Bank of America (July 6, 2007)
CAP Services (June 29, 2007)
Coastal Enterprises Inc. (July 6, 2007)
Central Bank of Kansas City (July 6, 2007)
City of New Hamption (Iowa) Office of Economic Development Director (July 2, 2007)
Community Development Funding Inc. (May 29, 2007)
Community First Fund (July 3, 2007)
Community Vitality Center (June 28, 2007)
Delta Trust (July 16, 2007)
Enterprise Corporation of the Delta (July 6, 2007)
Impact Seven Inc. (July 6, 2007)
Iowa Association of Business and Industry (July 2, 2007)
Iowa Business Growth (June 26, 2007)
Iowa State Bar Association Economic Development Committee (June 27, 2007)
Mississippi Governor Haley Barbour (July 6, 2007)
National Housing & Rehabilitation Association (July 6, 2007)
NMTC Coalition (July 6, 2007)
NMTC Working Group (July 6, 2007)
Oak Hill Banks Community Development Corp. (July 3, 2007)
REC Investments, Dakotas America LLC, Rural Development Partners, and National Tribal Development Association (June 20, 2007)
Rural Opportunities Inc. (July 6, 2007)
Seastrunk Enterprise LLC (July 5, 2007)
Securty State Bank, Robert Rigler (June 25, 2007)
Security State Bank, John Rigler (July 2, 2007)
Sens. Baucus, Grassley (August 2, 2007)
Sen. Thad Cochran (July 3, 2007)
Travoi New Markets LLC (July 3, 2007)
Wasker, Dorr, Wimmer & Marcouiller PC (July 2, 2007)
Western Wisconsin Development Corporation (July 6, 2007)
Wisconsin Housing Ministry Partnership (July 6, 2007)
Quarterly New Markets Report (QNMR)
NMTC Working Group Comment Letter Regarding the Quarterly New Markets Report (April 20, 2010)
QEI Issuance Requirements
NMTC Working Group Comment Letter Regarding QEI Issuance Requirements (November 25, 2008)
Redemption
Novogradac Company LLP et al Comment Letter regarding Redemption Regulations for the New Markets Tax Credit (NMTC) Program (April 24, 2006)
Letter to Eric Solomon, Treasury Deputy Assistant Secretary for Tax Policy, Regarding "Redemption" of Qualified Equity Investments
Frank Altman, President, Community Reinvestment Fund USA (November 23, 2004)
Letter to Eric Solomon, Treasury Deputy Assistant Secretary for Tax Policy, Regarding Determination of Redemption of Principal
New Markets Tax Credit Coalition (November 12, 2004)
Joint Letter to IRS Requesting Guidance on Redemptions under Section 45D
Novogradac Company LLP/Nixon Peabody LLP (June 30, 2004)
Regulations Project
NMTC Working Group Letter Regarding New Markets Tax Credit Treasury Regulations Project – Clarifications
(March 13, 2009)
Transcript of the Dec. 12, 2008, IRS Hearing on Proposed Regulations(REG-149404-07) Modifying New Markets Tax Credit
(December 12, 2008)
Kutak Rock Comment Letter Regarding New Markets Tax Credit Treasury Regulations Project
(November 10, 2008)
NMTC Coaltion Comment Letter Regarding New Markets Tax Credit Treasury Regulations Project
(November 10, 2008)
NMTC Coalition's Outline of Topics for IRS Hearing on December 12, 2008 Regarding New Markets Tax Credit Treasury Regulations Project
(November 3, 2008)
NMTC Working Group Comment Letter Regarding New Markets Tax Credit Treasury Regulations Project
(November 7, 2008)
NMTC Working Group's Outline of Topics for IRS Hearing on December 12, 2008 Regarding New Markets Tax Credit Treasury Regulations Project
(November 3, 2008)
Reznick Group Comment Letter Regarding New Markets Tax Credit Treasury Regulations Project
(November 6, 2008)
Opportunity Finance Network Comment Letter Regarding New Markets Tax Credit Treasury Regulations Project
(November 5, 2008)
Bank of America Comment Letter Regarding New Markets Tax Credit Treasury Regulations Project
(October 7, 2008)
University of La Verne Comment Letter Regarding New Markets Tax Credit Treasury Regulations Project
(September 22, 2008)
Future Unlimited Law Comment Letter Regarding New Markets Tax Credit Treasury Regulations Project
(September 5, 2008)
NMTC Working Group New Markets Tax Credit Treasury Regulations Project Comment Letter (April 14, 2008)
Reinvestment Regulations
Novogradac & Company LLP Letter to Eric Solomon/IRS Regarding NMTC Reinvestment Regulations (July 31, 2006)
Reportable Transactions
Affordable Housing Tax Credit Coalition Comments Regarding regulations pertaining Section 4965 (August 11, 2006)
Targeted Populations
NMTC Working Group Targeted Populations Comment Letter
(December 23, 2008)
Ropes Gray Letter to Eric Solomon Acting Deputy Assistant Secretary for Tax Policy Regarding Targeted Populations Guidance Under Section 45D(e)(2) (February 28, 2006)
CDFI Coalition Letter to Matt Josephs/CDFI Fund Regarding the Designation of Targeted Populations as Low-Income Communities(July 8, 2005)
NMTC Coalition Letter to Matt Josephs/CDFI Fund Regarding the Designation of Targeted Populations as Low-Income Communities (July 11, 2005)
Novogradac Company LLP Letter to Matt Josephs/CDFI Fund Regarding the Designation of Targeted Populations as Low-Income Communities
(July 6, 2005)
Testimony, Speakers, Articles
Keynote Address of Director Donna Gambrell at the New Markets Tax Credit Coalition’s 7th Annual Conference
(
December 2, 2008)
NMTC Working Group's Outline Topics for IRS Hearing on December 12, 2008 Regarding New Markets Tax Credit Treasury Regulations Project
(November 3, 2008)
Testimony of Rep. Steve Chabot, R-Ohio, Before the Subcommittee on Select Revenue Measures of the House Committee on Ways and Means
(September 26, 2006)
Remarks by Arthur A. Garcia, Director of the Community Development Financial Institutions Fund, at Boston Federal Home Loan Bank’s New Markets Tax Credit Program Summit
(September 30, 2005)
Sen. Snowe Introductory Remarks on S. 1800, New Markets Tax Credit Reauthorization Act of 2005
(September 29, 2005)
Transcript of IRS Hearing on Temporary and Proposed NMTC Regulations
(June 2, 2004)
New Markets Tax Credit And Economic Substance Doctrine: Senate Floor Colloguy
(May 11, 2004)
Treasury Announces the Appointment of Art Garcia to Serve As Director of the Community Development Financial Institutions Fund
(May 10, 2004)
Assistant Treasury Secretary Abernathy Testimony On the FY 2005 Budget Request for the CDFI Fund
(March 17, 2004)
Assistant Treasury Secretary Abernathy Announcement of Owen M. Jones as Acting Director of CDFI Fund
(February 25, 2004)
Treasury Secretary Snow Announcement of Director Tony Brown's Departure from the CDFI Fund
(February 17, 2004)
Tony Brown's Remarks to the CDFI Coaltion's 2004 CDFI Institute
(February 5, 2004)
Tony Brown's Remarks to the New Markets Tax Credits Coalition
(October 15, 2003)
Tony Brown's Remarks at the New Markets Tax Credits Briefing
(July 31, 2003)
CDFI Fund Workshop Presentation
(August 6, 2003)
CDFI Fund Workshop Agenda
(August 6, 2003)
Testimony of Tony T. Brown, CDFI Fund Director at Hearing on FY 2004 Appropriations
(February 27, 2003)
IPED: New Markets Tax Credit
Power Point Presentation
By: Michael J. Novogradac, Novogradac & Company LLP & Herb Stevens, Nixon Peabody, LLP
Treasury Department's Detailed Description of President Bush’s Dividend Exclusion Proposal from the Jobs and Growth Package
(January 21, 2003)
"Bush Dividends Exclusion Proposal: Potential Adverse Effects on Real Estate Tax Credits," by Michael J. Novogradac, CPA
(January 20,2003)
Tony Brown Speech to the New Markets Tax Credit Coalition First Annual Conference
(October 30, 2002)
"New Markets Program Offers Versatile New Tax Credit"
(By Michael J. Novogradac, CPA, Scotsman Guide Commercial Lender, August 2002)
"Bank Enterprise Awards and New Markets Tax Credits: Two Tools to Increase the Flow of Private Capital in Targeted Markets"
(Community Developments, Summer 2002)
Cliff Kellogg's Keynote Address to Novogradac & Company LLP's New Markets Tax Credit Conference
(June 7, 2002)
Remarks by Tony Brown, CDFI Fund Director, to the Annual Conference of the Community Development Venture Capital Alliance
(March 5, 2002)