Comment Letters

2022

LIHTC Working Group Letter to IRS about REG-113068-22 Section 42, LIHTC Average Income Test Regulations
Proposed/Temporary Treasury Regulation Section 1.42-19T
Dec. 12, 2022

LIHTC Working Group Letter to IRS about Public Comment for Notice 2022-48
Nov. 4, 2022

LIHTC Working Group Letter to NCSHA about Recommended Practices in Housing Credit Administration
Aug. 30, 2022

LIHTC Working Group Letter to IRS about Public Comment on 2022-2023 Priority Guidance Plan
June 3, 2022

2021

LIHTC Working Group Letter to OCC about Docket ID OCC-2021-0014 (Community Reinvestment Act Regulations)
Oct. 29, 2021

LIHTC Working Group Letter to IRS on Recommendations for 2021-2022 Priority Guidance Plan
May 28, 2021

LIHTC Working Group Letter to Federal Reserve Board about Community Reinvestment Act Proposed Rulemaking
Feb. 16, 2021

LIHTC Working Group Letter to IRS on 4% Minimum Rate Established in the Consolidated Appropriations Act of 2021
Feb. 11, 2021

2020

LIHTC Working Group Letter to IRS on Proposed Average Income Test Regulations
Dec. 29, 2020

LIHTC Working Group Letter to IRS on Proposed Regulations Section 1.163(j)-6(h)(5) Limitation of Business Interest
Nov. 2, 2020

2017

LIHTC Working Group Comment Letter of NCSHA Draft Recommended Practices for Housing Credit Administration
Aug. 11, 2017

2016

LIHTC Working Group Comment Letter on the 2016-2017 Priority Guidance Plan
May 16, 2016

LIHTC Working Group Comment Letter on Proposed Rule on Enterprise Duty to Serve Underserved Markets
March 17, 2016

2015

LIHTC Working Group Comment Letter on CTCAC Proposed Revisions to Selected Sections (PRSS) of the July 16, 2015 Proposed Regulation Changes
September 30, 2015

LIHTC Working Group Comment Letter on CTCAC July 16, 2015 Proposed Regulation Changes
August 31, 2015

LIHTC Working Group Comment Letter on Notice 2015-27: Priority Guidance Plan
May 1, 2015

LIHTC Working Group Comment Letter on LIHTC Tax Reform
April 15, 2015

LIHTC Working Group Comment Letter on Tenant Relocation Costs
February 6, 2015

LIHTC Working Group Comment Letter on the GASB Exposure Draft - Tax Abatement Disclosures
January 30, 2015

2014

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

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

LIHTC Working Group Letter to the Internal Revenue Service on the Section 42 Audit Technique Guide
March 28, 2014

LIHTC Working Group Letter to the Treasury on Temporary Relief for Buildings Earning 4 Percent Credits Affected by Presidentially Declared Disasters
March 28, 2014

LIHTC Working Group Letter to the Senate Finance Committee on Proposed Cost Recovery Reform
January 15, 2014

2013

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

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

LIHTC Working Group Letter To the Internal Revenue Service Regarding Notice 2013-22, 2013-2014 Guidance Priority List
May 1, 2013

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

LIHTC Working Group Letter on Conflicting Affordable Housing Program Requirements
February 27, 2013

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

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

2012

LIHTC Working Group Letter Regarding the Subcommittee on Select Revenue Measures Hearing on Certain Expiring Tax Provisions
May 7, 2012

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

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

2011

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

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

2010

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

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

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

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 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 to HUD Regarding LIHTC Tenant Data Collection
March 26, 2010

LIHTC Working Group Letter to HUD Regarding National Housing Trust Fund Regulations
March 25, 2010

2009

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: Recapture Issues Related to Section 1602 of the Recovery Act
July 30, 2009

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

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

Definition of Substantially Assisted, Financed, or Operated in the Housing and Economic Recovery Act (HERA)
March 11, 2009