Once a year, the landlord passes around something labeled "Annual Recertification Notice 30 Day", in which a lot of personal financial questions to which they presumably already know the answers are asked yet again, due to "federal regulations and program rules".
I was glaring angrily at this thing for about the 16th consecutive day what possible difference could it make to anyone, with the possible exception of the vultures at the Internal Revenue Service, how much money I have in my 401(k) account? when it occurred to me that this might have something to do with Federal rent subsidies (the infamous Section 8). While I don't receive any kind of rent subsidy my income is low, but it isn't that low the Federal mentality holds that if even one person is the beneficiary of taxpayer-financed government largesse, the entire group is subject to Federal regulations. This, of course, is outrageous, but unfortunately it isn't unprecedented.
So I poked around the Net for a few minutes, and it didn't take too long before I found the IRS's own overview of a low-income housing credit for property owners, which is part of something called the Market Segment Specialization Program, evidently with nomenclature help from a buzzword generator. In general, this credit, with all its voluminous requirements, is intended to encourage investment in rental properties that target lower-income tenants.
Now, obviously this is just one section of the tax code, and God only knows how many sections there are. But irrespective of whether this is the specific rule governing my particular situation, basically I'm being asked to provide personal information for the benefit of someone else's tax bill, and on the pretext of fighting poverty yet. I find this more than a little bit horrendous. Can I be sure that this is the correct regulation? Not yet. The certification form has the following little jewel of presumption preceding the signature block:
I/We acknowledge that all of the above information is relevant to the status under federal income tax law of the interest on the bonds issued to finance acquisition and rehabilitation of the apartment for which application is being made. I/We consent to the disclosure of such information to the Authority, the holders of such bonds and any trustee acting on this behalf.
Believing that I should always question Authority, and if at all possible before Authority questions me, I added the following to my form:
"Under provisions of the law governing the acquisition for which this information is being provided, the undersigned requests that a copy of the enabling legislation or the regulations pertinent to this certification be provided for my inspection."
Let's see what if anything this brings.
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Copyright © 2000 by Charles G. Hill