Testimony, Comments, Correspondence
On January 15, IRS issued Notice 2021-12 providing temporary relief to state Housing Credit allocating agencies, owners, and residents of Housing Credit properties in response to the COVID-19 pandemic. Notice 2021-12 extends the deadlines and waivers originally provided by IRS under Notice 2020-53 and expands relief measures to include additional relief not previously provided by the Service. This matrix compares the accommodations IRS provides in Notice 2021-12 to recommendations for COVID-19 guidance that NCSHA sent to IRS in a November 16 letter and to existing disaster relief IRS provides under Revenue Procedures 2014-49 and 2014-50, which are applicable in cases of a presidentially-declared major disaster.
This January 8, 2021, document details the recommendations NCSHA made to the Treasury Department for guidance related to the $25 billion Emergency Rental Assistance program.
On January 6, 2021, NCSHA submitted this comment letter to the U.S. Department of Housing and Urban Development in response to its proposed rule that would implement changes affecting the Housing Choice Voucher tenant-based and Project-Based Voucher programs as authorized by the Housing Opportunity Through Modernization Act of 2016 (HOTMA) as well as additional regulatory changes intended to reduce the burden on public housing agencies.
On December 17, 2020, NCSHA submitted this comment letter to the Internal Revenue Service in response to its proposed rule that would establish new Low Income Housing Tax Credit regulations related to the Average Income Test (AIT) minimum set-aside and modify existing regulations related to the Next Available Unit rule for purposes of implementing the AIT.
The A Call To Invest In Our Neighborhoods (ACTION) Campaign sent this letter to the Biden-Harris Transition Agency Review Teams for the Departments of the Treasury, Housing and Urban Development, and Agriculture outlining how the Biden Administration can work with ACTION to further increase affordable housing production and preservation with the Housing Credit by supporting congressional action and through regulatory changes.
National Sign-On Letter Supporting NCSHA Recommendations to IRS on Housing Credit COVID-19 Regulatory Relief
This letter, signed by 140 organizations from across the nation, urges IRS to enact Housing Credit COVID-19 regulatory relief requested by NCSHA in its November 16, 2020, letter to the IRS and Treasury.
On November 24, 2020, NCSHA sent this letter to the U.S. Department of Housing and Urban Development urging immediate action to extend the temporary relief provided by the pair of April 10, 2020, memoranda on the availability of waivers and suspensions of HOME Investment Partnership program requirements and HOME-Assisted Tenant-Based Rental Assistance for Emergency and Short-Term Assistance in response to the COVID-19 pandemic.
On November 16, 2020, NCSHA sent this letter to the Internal Revenue Service and the U.S. Department of the Treasury urging them to extend the temporary Housing Credit relief provided by IRS Notice 2020-53 and to make other necessary program accommodations as the COVID-19 pandemic continues to disrupt development and construction activities and the operation of Housing Credit properties. One hundred and forty organizations from across the nation signed a letter in support of NCSHA’s requests. Separately, the National Association of Home Builders (NAHB) sent a letter to IRS echoing NCSHA’s recommendations.
NCSHA offers these analyses of the 2020 election results.