Legislative and Regulatory Priorities

1
We urge Congress to increase affordable rental housing production by expanding and strengthening the Housing Credit as part of 2025 tax legislation. We encourage enactment of the proposals included in the Affordable Housing Credit Improvement Act (AHCIA), comprehensive, bipartisan legislation to expand and strengthen the Housing Credit. We especially urge immediate enactment of the Housing Credit production proposals in the AHCIA with the greatest impact, which were included in the bipartisan Tax Relief for American Families and Workers Act of 2024:
- Restoring and expanding upon the temporary 12.5 percent allocation increase that was first enacted under President Trump’s first term but was not extended, and
- Lowering the bond financing threshold test.
We also urge the inclusion of new basis boosts for underserved areas and populations, such as rural communities.
2
In addition to the AHCIA proposals listed above, the AHTCC supports other policies to support a robust Housing Credit investment market as part of 2025 tax legislation. This may include addressing the impact on affordable housing resulting from other changes elsewhere in the tax code, such as the base erosion and anti-abuse tax (also known as BEAT), or enacting new policies, such as modifying Section 39 of the tax code to allow Housing Credits to be carried back three years, and easing the general business credit limitation on the ability to use Housing Credits by allowing investors to reduce their tax liability beyond the current limits when using the Housing Credit.
3
We urge the Trump Administration to protect Housing Credit investment through any changes to the Community Reinvestment Act regulations, lower Housing Credit risk weighting as part of the Basel III framework, and otherwise support affordable housing investment in any other regulations that may directly or indirectly impact the Housing Credit.
4
We encourage the Internal Revenue Service to continue to provide Housing Credit regulatory flexibilities that improve our ability to finance, develop and operate affordable housing. In addition to flexibilities that may be needed to address continued barriers and challenges as they arise, we encourage the IRS to enact any AHCIA policy proposals that are within the IRS’ purview.