Comment Letters and Testimony

America’s Affordable Housing Crisis: Challenges and Solutions

Member Statements
Orrin G. Hatch (R - UT)

Witnesses
Daniel Garcia-Diaz
Director, Financial Markets And Community Investment
United States Government Accountability Office
Washington

Grant S. Whitaker
President
National Council of State Housing Agencies
Washington , DC

The Honorable Katherine M. O’Regan, PhD
Professor Of Public Policy And Planning; Faculty Director, Furman Center For Real Estate And Urban Policy, Robert F. Wagner Graduate School Of Public Service
New York University
New York , NY

Kirk McClure, PhD
Professor, Urban Planning Program, School Of Public Policy And Administration, College Of Liberal Arts And Sciences
University of Kansas
Lawrence , KS

Granger MacDonald
Chairman Of The Board Of Directors
National Association of Home Builders
Washington , DC
 

Affordable Housing Trust Fund

NCSHA's Comments on Housing Trust Fund Proposed Rule
December 28, 2010

LIHTC Working Group Letter Regarding Proposed Regulations for the National Housing Trust Fund
December 28, 2010

Testimony by Brian Montgomery, assistant secretary for housing-federal housing commissioner, HUD, for House Financial Services Committee Hearing on H.R. 2895, the National Affordable Housing Trust Fund Act of 2007
July 19, 2007

Testimony of Sheila Crowley, president, National Low-Income Housing Coalition for House Financial Services Committee Hearing on H.R. 2895, the National Affordable Housing Trust Fund Act of 2007
July 19, 2007

Testimony of William D. Euille, mayor, Alexandria, Va., on behalf of the U.S. Conferences of Mayors for House Financial Services Committee Hearing on H.R. 2895, the National Affordable Housing Trust Fund Act of 2007
July 19, 2007

Testimony of JoAnne Poole, broker/owner, Poole Realty on behalf of the National Association of Realtors for House Financial Services Committee Hearing on H.R. 2895, the National Affordable Housing Trust Fund Act of 2007
July 19, 2007

Testimony of Dave Robersts, CEO and president of Lutheran Homes Society for House Financial Services Committee Hearing on H.R. 2895, the National Affordable Housing Trust Fund Act of 2007
July 19, 2007

Testimony of Barbara Thompson, executive director, National Council of State Housing Agencies for House Financial Services Committee Hearing on H.R. 2895, the National Affordable Housing Trust Fund Act of 2007
July 19, 2007

Testimony of Hillary O. Shelton, director , Washington bureau, National Association for the Advancement of Colored People for House Financial Services Committee Hearing on H.R. 2895, the National Affordable Housing Trust Fund Act of 2007
July 19, 2007

Testimony of Megan Sandal, assistant professor of pediatrics, Boston University School of Medicine for House Financial Services Committee Hearing on H.R. 2895, the National Affordable Housing Trust Fund Act of 2007
July 19, 2007

Testimony of Joe L. Myer, executive director, NCALL Research Inc., on behalf of National Rural Housing Coalition for House Financial Services Committee Hearing on H.R. 2895, the National Affordable Housing Trust Fund Act of 2007
July 19, 2007

H.R. 2895 National Affordable Housing Trust Fund Act of 2007
June 28, 2007

American Recovery and Reinvestment Act of 2009

Reissued LIHTC Working Group Letter Regarding Recapture Rules Surrounding Section 1602 of the American Recovery and Reinvestment Act of 2009
August 2, 2010

Reissued LIHTC Working Group Letter Regarding Definition of Substantially Assisted, Financed, or Operated in the Housing and Economic Recovery Act (HERA)
July 14, 2010

LIHTC Working Group Letter: Recapture Issues Related to Section 1602 of the Recovery Act
July 30, 2009

Letter from Reps. Rangel and Frank to Treasury Secretary Geithner Urging Action on LIHTC Exchange Guidance
March 25, 2009

National Association of Home Builders Letter to Sen. Maria Cantwell in Support of her Amendment to Accelerate the LIHTC
January 26, 2009

National Association of Home Builders Letter to the Senate Finance Committee Recommending Proposals to Ensure the Long-Term Vitality of the LIHTC Program
January 22, 2009

Coalition of Affordable Housing Industry Participants' Letter Urging Support for the LIHTC be Included in Economic Recovery Bill
January 15, 2009

Coalition of Affordable Housing Industry Participants' Letter to Chairman Charlie Rangel Regarding Legislative Priorities to Stimulate Investment into Low Income Housing Tax Credit (LIHTC) Properties
January 6, 2009

Community Reinvestment Act

LIHTC Working Group Comment Letter on the Proposed Changes to the Interagency Q&A Regarding Community Reinvestment
November 10, 2014

LIHTC Working Group Letter to the GAO on the Effect of CRA on LIHTC Investments
January 16, 2013

NCSHA Letter to Federal Regulators Asking Them to Improve CRA Regulations
August 31, 2010

Community Reinvestment Act: Towards a sustainable national CRA policy for Low Income Housing Tax Credit (LIHTC) investments
August 31, 2010

Dividend Exclusion Proposal

Letter from Asst. Treasury Secretary for Tax Policy Pamela F. Olson to Barbara J. Thompson regarding Impact of Bush Administration's Growth and Jobs Plan on the LIHTC
July 25, 2003

Letter to Senate Finance Committee Chairman Charles Grassley and Ranking Member Max Baucus Urging Preservation of the LIHTC in crafting the final version of the Jobs and Growth Package
May 21, 2003

Letter from Asst. Treasury Secretary for Tax Policy Pamela F. Olson to Barbara J. Thompson regarding Impact of Bush Administration's Growth and Jobs Plan on the LIHTC
April 8, 2003

Letter from Treasury Secretary John W. Snow Assuring the National Association of Home Builders of the Bush Administration's Commitment to the Low Income Housing Tax Credit Program
April 8, 2003

Letter from NCSHA Executive Director Barbara J. Thompson regarding a Correction to the MBAA Report
March 20, 2003

MBAA Multifamily Alert: Notice of Clarification
March 20, 2003

Estimated Impact of Major Components of the Bush Administration's Growth and Jobs Plan on Housing and the Economy by the Mortgage Bankers Association of America
March 10, 2003

Testimony of Richard H. Godfrey Jr., Executive Director, Rhode Island Housing and Mortgage Finance Corporation, Providence, Rhode Island, and Vice President, National Council of State Housing Agencies Before the House Committee on Ways and Means
March 6, 2003

National Council of State Housing Agencies Letter to Treasury Secretary John Snow regarding the Dividend Exclusion Proposal's Effect on Affordable Housing Production
February 25, 2003

Statement of Secretary Shaun Donovan
February 25, 2003

Industry Joint Letter "The Impact of the Administrations Dividend Tax-Exemption Proposal on the Low Income Housing Tax Credit"
January 27, 2003

Treasury Department's Detailed Description of President Bush’s Dividend Exclusion Proposal from the Jobs and Growth Package
January 21, 2003

What a Dividend Tax-Exemption Rule Could Mean for Affordable Housing and Community Development Investments
January 20, 2003

Rep. Charles Rangel (D-N.Y.) Letter to HUD Secretary Mel Martinez Regarding the Adverse Impact of the Dividend Exclusion Proposal on the Low-Income Housing Tax Credit Program
January 9, 2003

Economic Substance

LIHTC Working Group Letter Seeking Guidance Related to Codification of Economic Substance and Low-Income Housing Tax Credits
October 27, 2010

Encourage LIHTC Investment

H.R. 3661 Support Letter from Reps. Tiberi and Neal
February 28, 2012

Industry Consensus Letter: Proposals to Broaden LIHTC Investor Market, Produce Housing
August 3, 2009

National Association of Home Builders Letter to Sen. Maria Cantwell in Support of her Amendment to Accelerate the LIHTC
January 26, 2009

National Association of Home Builders Letter to the Senate Finance Committee Recommending Proposals to Ensure the Long-Term Vitality of the LIHTC Program
January 22, 2009

AHTCC Proposals to Stimulate Investment in Housing Credit Development
November 10, 2008

Enterprise Letter to IRS Regarding Proposed Update of Utility Allowance Regulations

Enterprise Letter to IRS Regarding Proposed Update of Utility Allowance Regulations
September 17, 2007

Global Bond Ratings

AHTCC Letter to Moody’s Investors Service Regarding Assignment of Global Ratings to Tax-Exempt Municipal Obligations
June 30, 2008

Guidance Priority List

LIHTC Working Group 2014-2015 Guidance Priority Letter Draft
May 13, 2014

LIHTC Working Group Letter Proposing an Issue for Addition to the 2012-2013 Guidance Priority List
April 30, 2012

LIHTC Working Group Letter to the Internal Revenue Service Regarding Notice 2011-39: Priority Guidance Plan
May 31, 2011

NABL Comment Letter Regarding 2009-2010 Guidance Priority List
May 28, 2009

Hold Harmless Rule

LIHTC Working Group Letter on Rural Designation Uncertainty
January 30, 2013

LIHTC Working Group Letter to IRS Regarding Income Limits and HUD Hold Harmless Provisions in the Housing and Economic Recovery Act of 2008
July 9, 2010

LIHTC Working Group Letter: Response to HUD Docket No. FR-5323-N-01: Request for Comments on Ending "Hold Harmless" Policy
November 2, 2009

LIHTC Working Group Letter to IRS Regarding HUD Hold Harmless Provisions in the Housing and Economic Recovery Act of 2008
April 15, 2009

HOPE VI/H.R. 1614

Prepared Statement of Michael Liu, assistant secretary for public and Indian housing, U.S. Department of Housing and Urban Development, before the U.S. House Financial Services Subcommittee on Housing and Community Opportunity
April 29, 2003

Testimony of Renee Glover, chief executive officer of the Atlanta Housing Authority on behalf of the Council of Large Public Housing Authorities, before the U.S. House Financial Services Subcommittee for Housing and Community Opportunity
April 29, 2003

Housing Assistance for Hurricane Victims

NYSAFAH Letter Urging Introduction of Senate Hurricane Sandy Tax Relief Bill
September 27, 2013

Section 42(i)(2)(D) and CDBG Funds for Areas Impacted by Hurricanes Katrina, Rita and Wilma
January 8, 2007

NCSHA Letter Urging Extension of Provisions in IRS Notices 2005-69 and 2006-11
August 28, 2006

HUD 2530 Filing Requirements

Industry Sign-on Letter in Support of H.R. 1675, Preservation Approval Process Improvement Act of 2007
March 27, 2007

HUD Secretary Nomination

Statement of Chairman Christopher J. Dodd: Nomination Hearing for Shaun Donovan, HUD Secretary-Designate
January 13, 2009

Statement of Shaun Donovan, Nominee for Secretary of the U.S. Department of Housing and Urban Development
January 13, 2009

Improve the LIHTC Program

Congressional Letter to the Federal Housing Finance Agency in Support of Affordable Rental Housing and Reforming the Mortgage Finance System
January 23, 2014

AHTCC Letter to Rep. Rangel in Support of H.R. 1491
March 15, 2007

AHTCC Letter to Reps. Davis and Ramstad in Support of H.R. 1491
March 14, 2007

Dear Colleague Letter in support of H.R. 4873
June 27, 2006

Affordable Housing Tax Credit Coalition's Comments in response to NCSHA Working Group Proposals
September 10, 2004

Income Averaging

NCSHA Letter to IRS and Treasury on Income Averaging Implementation
National Council of State Housing Agencies, June 13, 2018

Interpretation of Section 42(h)(4) of the Internal Revenue Code

Oregon State Treasurer letter to Donald Lee Korb, IRS Chief Counsel, and Eric Solomon, Treasury Deputy Assistant Secretary, Regulatory Affairs
January 28, 2005

LIHTC Consensus Proposals

Prudential Financial Vice President & Chief Tax Officer James J. Shea Letter toTreasury Tax Legislative Counsel Josh Odintz Regarding H.R. 4109, an Extension of the Low Income Housing Credit Carryback Period
January 28, 2010

Sens. Kerry, Cantwell Letter to Senate Finance Committee Leadership in Support of the LIHTC Consensus Proposals
December 17, 2009

Industry Consensus Letter: Proposals to Broaden LIHTC Investor Market, Produce Housing
October 26, 2009

Low-Income Housing Tax Credit Investment Survey
October 8, 2009

AHTCC Announces Legislative Priorities for 2009
May 19, 2009

Miscellaneous LIHTC

Moody's Investors Services: Outlook Update: US State Housing Finance Agencies Outlook Revised to Stable
October 8, 2013

Remarks Prepared for Jack Kemp, HUD Secretary, at the Heritage Foundation Lecture
June 6, 1990

A Vision of Hope: America's New War on Poverty - Remarks Prepared for Delivery by Secretary Jack Kemp to the National League of Cities
November 28, 1989

Remarks to National Press Club Luncheon by Jack Kemp, Sec. of Housing & Urban Development
November 15, 1989

Abolish HUD or Abolish Poverty?" Remarks by Hon. Jack Kemp to the Mortgage Bankers Association
October 23, 1989

NCSHA Recommended Practices

Novogradac & Company LLP Comments Regarding Potential Changes to NCSHAs Housing Credit Recommended Practices
September 27, 2010

Non-Discrimination Against Limited English Proficient (LEP) Persons

National Housing Provider Trade Associations' Joint Commentary Regarding HUD's Proposed Guidance
January 20, 2004

Notice 2009-44 (Treatment of Utility Costs Paid by Rent-Restricted Unit Tenant Based on Submetering)

Michael Uccellini, Institute of Real Estate Management, Comments on IRS Notice 2009-44
July 27, 2009

Michael Kotin, Kay-Kay Realty Corp., Comments on IRS Notice 2009-44
May 11, 2009

South Carolina State Housing Finance and Development Authority Comments on IRS Notice 2009-44
April 2009

Florida Tenant Monica Barronton Comments on IRS Notice 2009-44
April 2009

Preserve the Community Development Block Grant (CDBG) Program

Dear Colleague Letter to the Senate Budget Committee on preserving the Community Development Block Grants and related programs
February 16, 2005

Prevailing Wage Requirements

Department of Industrial Relations Ruling: Section 42 federal tax credits and tax-exempt bonds do not trigger prevailing wage
February 25, 2005

California Housing Consortium letter to Calif. Gov. Schwarzenegger regarding prevailing wage requirements for affordable housing developments mandated by CA SB 975
January 5, 2004

California S.B. 360 Public works: Prevailing Wages: Exclusions
September 2003

CA S.B. 972 Amending Prevailing Wage Law for Affordable Housing
September 28, 2002

Calif. S.B. 975, Prevailing Wage Law for Affordable Housing
August 30, 2001

Proposal to Double the LIHTC Cap in 2006

Reps. William Jefferson, D-La., and Phil English, R-Pa., "Dear Colleague" Letter in Support of Doubling the LIHTC
May 24, 2005

Sen. Charles Schumer Keynote Address to the Annual Awards Luncheon of the New York Housing Conference and National Housing Conference
December 7, 2004

Proposed Regulation and Guidance

NSCHA Comments on IRA Compliance Monitoring Regulations
May 6, 2019

American Bar Association Section of Taxation Comment Letter to IRS on Proposed Treasury Regulation 1-42-18 Qualified Contracts
September 28, 2007

National Housing Law Project
September 18, 2007

National Council of State Housing Agencies Comment Letter to IRS on Proposed Treasury Regulation 1-42-18 Qualified Contracts
September 17, 2007

Affordable Housing Tax Credit Coalition Comment Letter to IRS on Proposed Treasury Regulation 1-42-18 Qualified Contracts
September 17, 2007

Novogradac & Company LLP Comment Letter to IRS on Proposed Treasury Regulation 1-42-18 Qualified Contracts
September 17, 2007

New York State Division of Housing and Community Renewal Comment Letter to IRS on Proposed Treasury Regulation 1-42-18 Qualified Contracts
September 17, 2007

City of New York Department of Housing Preservation and Development Comment Letter to IRS on Proposed Treasury Regulation 1-42-18 Qualified Contracts
September 15, 2007

Georgia State Trade Association of Nonprofit Developers Comment Letter to IRS on Proposed Treasury Regulation 1-42-18 Qualified Contracts
September 14, 2007

Arizona Department of Housing Comment Letter to IRS on Proposed Treasury Regulation 1-42-18 Qualified Contracts
September 7, 2007

Washington State Housing Finance Commission Comment Letter to IRS on Proposed Treasury Regulation 1-42-18 Qualified Contracts
September 7, 2007

Public Comment Letters and Testimony

Poverty and Race Research Action Council Comment Letter on IRS Notice 2017-77
February 10, 2017

National Council of State Housing Agencies Comment Letter on IRS Notice 2016-77
February 10, 2017

Local Initiatives Support Corporation Comment Letter on IRS Notice 2016-77
February 10, 2017

National Housing Trust Comment Letter on IRS Notice 2016-77
February 10, 2017

Inclusive Communities Project, Inc. Comment Letter on IRS Notice 2016-77
February 10, 2017

Minnesota Housing Finance Agency Comment Letter on IRS Notice 2016-77
February 10, 2017

National Housing Law Project Letter to IRS Regarding Proposed Update of Utility Allowance Regulations
September 18, 2007

Utah Housing Corporation Letter to IRS Regarding Proposed Update of Utility Allowance Regulations
September 17, 2007

National Association of Home Builders Letter to IRS Regarding Proposed Update of Utility Allowance Regulations
September 17, 2007

National Affordable Housing Management Association Letter to IRS Regarding Proposed Update of Utility Allowance Regulations
September 17, 2007

NCSHA Letter to IRS Regarding Proposed Update of Utility Allowance Regulations
September 17, 2007

NMHC Letter to IRS Regarding Proposed Update of Utility Allowance Regulations
September 13, 2007

Arizona Department of Housing Letter to IRS Regarding Proposed Update of Utility Allowance Regulations
September 7, 2007

Nationwide Housing Preservation Companies Letter to IRS Regarding Proposed Update of Utility Allowance Regulations
September 6, 2007

Washington State Housing Finance Commission Letter to IRS Regarding Proposed Update of Utility Allowance Regulations
August 27, 2007

Industry Letter Urging IRS to Consider Changing Regulations Governing Utility Allowances
April 12, 2005

Qualified Contract Price

Oregon Housing and Community Services letter to Acting Assistant Secretary for Tax Policy Eric Solomon Regarding Qualified Contract Price
November 20, 2006

South Carolina State Housing Finance and Development Authority letter to Acting Assistant Secretary for Tax Policy Eric Solomon Regarding Qualified Contract Price
November 13, 2006

Indiana Housing and Community Development Authority letter to Acting Assistant Secretary for Tax Policy Eric Solomon Regarding Qualified Contract Price
November 9, 2006

South Dakota Housing Development Authority letter to Acting Assistant Secretary for Tax Policy Eric Solomon Regarding Qualified Contract Price
November 9, 2006

Washington State Housing Finance Commission letter to Acting Assistant Secretary for Tax Policy Eric Solomon Regarding Qualified Contract Price
November 9, 2006

Alabama Housing Finance Authority letter to Acting Assistant Secretary for Tax Policy Eric Solomon Regarding Qualified Contract Price
November 8, 2006

Virginia Housing Development Authority letter to Acting Assistant Secretary for Tax Policy Eric Solomon Regarding Qualified Contract Price
November 2006

SEC Interpretation of LIHTC Public Fund Investments

Rep. Barney Frank Letter to SEC Chairman Christopher Cox Regarding SEC Audit Process for LIHTC Partnerships
September 18, 2007

AHTCC, NAHB, Housing Advisory Group Letter to Rep. Barney Frank Regarding SEC Audit Process for LIHTC Partnerships
September 6, 2007

Section 4965 (Exempt Organizations Prohibited Tax Shelter Transactions)

Novogradac & Company LLP Comment Letter Regarding Notice 2006-65
August 16, 2006

Affordable Housing Tax Credit Coalition Comments Regarding regulations pertaining Section 4965
August 11, 2006

State Tax Credits

Office of the Comptroller of the Currency (OCC) Interpretive Letter #948
December 2002

Statements, Letters, Testimony

LIHTC Working Group Letter to the Financial Stability Oversight Council Regarding the Implementation of the Prohibitions on Proprietary Trading and Certain Relationships with Hedge Funds and Private Equity Funds
November 5, 2010

Tax Reform

Statement of the A Call To Invest in Our Neighborhoods (ACTION) Campaign: "In Response to the Ways and Means Committee Hearing on “How Tax Reform Will Grow Our Economy and Create Jobs” 
May 18, 2017 

Adrianne Todman, District of Columbia Housing Authority
April 16, 2015

Brad Fennell, WC Smith
April 16, 2015

James M. Evans, Quadel Consulting
April 16, 2015

Sheila Crowley, National Low-Income Housing Coalition
April 16, 2015

Letter to the Senate Discussing the Status of Tax Exempt Municipal Bonds
March 26, 2015

ACTION Campaign Letter Urging Inclusion of Minimum Low-Income Housing Tax Credit Rates in Tax Extenders Legislation
June 17, 2014

Hilary Shelton, NAACP
November 7, 2013

Rick Judson, National Association of Home Builders
November 7, 2013

Sheila Crowley, National Low Income Housing Coalition
November 7, 2013

Douglas Holtz-Eakin, American Action Forum
November 7, 2013

Ethan Handelman, National Housing Conference
November 7, 2013

Pres. Barack Obama's "A Better Bargain for the Middle Class: Housing" Plan
August 6, 2013

Tax Reform Joint Real Estate Industry Letter
July 23, 2013

LIHTC Working Group Letter to the Ways and Means Committee on Tax Reform and Residential Real Estate
May 8, 2013

NCSHA Letter to the Ways and Means Committee in Support of Preserving and Strengthening the LIHTC and Tax-Exempt Housing Bond Program
April 15, 2013

LISC Tax Reform Working Group on Financial Services Letter to the Ways and Means Committee on Tax Reform
April 15, 2013

National Housing Trust Real Estate Tax Reform Working Group Letter to the Ways and Means Committee on Real Estate Tax Reform
April 15, 2013

Enterprise Letter to the Committee on Ways and Means Regarding Real Estate Tax Reform
April 15, 2013

LIHTC Working Group Letter to the Committee on Ways and Means on Real Estate Tax Reform
April 15, 2013

Letter to the Committee on Ways and Means Regarding Multifamily Housing and Tax Reform
April 4, 2013

Letter to the Senate Discussing the Status of Tax Exempt Municipal Bonds
March 8, 2013

Tax-Exempt Organizations

State, Municipal Government Associations' Letter to House, Senate Tax Committee Leaders on Exemptions for Municipal Bonds
March 2, 2016

Rep. Charles Boustany Letter to IRS Commissioner Shulman Requesting Information on the Tax-Exempt Sector, including audit and compliance activities
October 6, 2011

TEFRA Requirements for Bonds Under Section 147

NABL Guidance Recommendations on TEFRA Public Approval Requirements for Bonds
January 24, 2007

Treatment of LIHTCs Under the Troubled Asset Relief Program (TARP)

AHTCC Letter to Members of Congress Regarding the Emergency Economic Stabilization Act of 2008
October 10, 2008

AHTCC Letter to the Treasury Department Regarding the Emergency Economic Stabilization Act of 2008
October 10, 2008

Treatment of the GSEs LIHTC Portfolios

Statement of FHFA Acting Director Edward J. DeMarco Concerning the Possible Transfer of Fannie Mae Low-Income Housing Tax Credits to Investors
November 5, 2009

Press Release: Fannie Mae Reports Third-Quarter 2009 Results
November 5, 2009

Affordable Housing Tax Credit Coalition Letter to Chairman Dodd and Chairman Frank Regarding Potential Sale of Freddie Mac's or Fannie Mae's Existing LIHTC Portfolios
June 29, 2009

Letter from Ways and Means Chairman Rangel to Secretary Paulson discouraging sale of GSEs LIHTC Portfolios
November 18, 2008

Unit Protection Rule

AHTCC Memo to IRS Regarding Its Position on the Unit Protection Rule
April 9, 2007

Utility Allowances

LIHTC Working Group Letter on Carryover Allocation and Utility Allowance Regulations
November 6, 2013

Industry Letter Urging IRS to Consider Changing its Regulations Governing Rent Adjustments at LIHTC Properties Where Residents Pay all or a Portion of Their Utilities
December 12, 2003

Statement by Sen. John Kerry (D-Mass.) on the Introduction of S 875, the Community Development Homeownership Tax Credit Act
April 10, 2003

Volcker Rule

LIHTC Working Group Letter on the Proposed Rule Implementing the Volcker Rule
February 13, 2012

Other

Senator Letter to IRS: Allow Veteran Housing Projects to Receive Tax-Exempt Bonds
March 15, 2019

Follow-Up Letter: LIHTC Regulatory Reform and the President’s Budget Proposal
March 20, 2016

Novogradac & Company LLP Comment Letter Regarding IRC Section 42: Conflicting Affordable Housing Program Requirements
February 27, 2013

Novogradac & Company LLP Comment Letter Regarding Form 8823: Low-Income Housing Credit Agencies Report of Noncompliance
August 29, 2011

Notice 2009-44: Utilities Paid by Tenant of Submetered Rent-restricted Unit
May 26, 2009

Industry Coalition Letter Seeking Guidance on Exchange Program
April 2, 2009

LIHTC Working Group Letter: Immediate Issues from the American Recovery and Reinvestment Act of 2009
March 16, 2009

LIHTC Industry Sign-On Letter Encouraging Inclusion of Housing Credit Provisions in Senate Stimulus Bill
February 3, 2009

Letter Regarding the Burdens Imposed by the Current Federal Income Tax System and the Need for Reform
February 2, 2011

Letter from Sen. Edward Kennedy to the Secretary of the Treasury
October 20, 2000

Senator George Mitchell Letter to Michael Novogradac Regarding the Future of the Low-Income Housing Tax Credit
November 4, 1993