LIHTC’s 25th year ends quietly; what’s ahead?
Compared to the regulatory upheaval of previous years, 2011 — the Low-Income Housing Tax Credit program’s 25th year — was relatively calm. For that — and for the program’s 25 years of success — we are grateful, even if the ever-changing nature of federal politics and priorities makes the program’s future uncertain.
The most significant LIHTC story of 2011 (other than its silver anniversary) was the second update to the IRS’s Guide to Completing Form 8823. The revision was released last winter and provided little content change but easier access to the document through the IRS website, which we didn’t have before. Some years we should simply be grateful for the status quo.
Actually, this year-end finds me more excited about the coming year than the prior one for several reasons. First off, I continue to be hopeful concerning the outcome of the Federal Alignment efforts undertaken by agencies involved in affordable rental housing in Washington. There is still one alignment report on Compliance in Fair Housing Memorandums of Understanding (MOUs) that I haven’t profiled in this forum yet, but plan to address in the new year. I will be at the National Council of State Housing Agencies’ Housing Finance Agency Institute in Washington, DC in January, which includes a session on the Federal Alignment initiative, so my analysis is not yet complete. Regardless, those of us who have been in this line of work for our whole careers are thrilled to know that the Powers That Be in our fair Capital city are finally communicating with one another on this level.
Secondly, I look forward to learning about the state of the updated Recommended Practices in Compliance Monitoring among state housing agencies in the coming year. Hopefully this will also be addressed in workshops at the gathering referenced above and I’ll be able to report to you on this issue as well. Considering all of the changes of the last decade and the fact that the current Recommended Practices are at least that old, it will be interesting to learn what the state agencies currently consider to be priorities for auditing tax credit properties and the Recommended Practice Forms that result from the update. We will, of course, keep you informed on these efforts and any other new developments in the industry as they occur.
Finally, to kick off the new year I would like to remind all of you who have been affected by the HERA provision that allowed for the Basic Allowance for Housing (BAH) exclusion from household income for military personnel at certain military installations since the Summer of 2008, that it expires on January 1, 2012, so please calculate accordingly!
Most of all, I would like to thank you for your continued participation in NCHM programs and monthly readership of our articles. Please enjoy your holidays and what we have left of this year, and I will especially look forward to keeping in touch with all of you in 2012.