Pcmh Shakespeare Avenue Housing Development Fund Corporation

“The members of the organization are the trustees of the postgraduate center of mental health.”

“The members, which are the trustees of the postgraduate center of mental health, have the ability to appoint and remove the board of directors as the governing body of the organization.”

“The bylaws may be amended, repealed or adopted by the members of the organization. Any bylaws adopted by the board may be may be amended or repealed by the board.”

“The organization did not have any board meetings during fiscal year 2017. The organization does not hold individual meetings; any comments pertaining to the residence are discussed during postgraduate center for mental health's board meetings and documented in their minutes.”

“The organization does not have any committees.”

“An outside Accounting firm and the organization have established the following review process to ensure that the information reported is complete and accurate. When the form 990 has been prepared, reviewed by management, and is ready to be filed with the internal revenue service, it is electronically sent to the board of directors for any comments. Any comments are then grouped, summarized and provided to the outside accountants. Each comment is documented and addressed. Once all of the comments have been cleared, the return is finalized and electronically filed with the IRS.”

“The organization follows the policies of its' parent company, postgraduate center for mental health, but has not formally adopted them as its' own policies.”

“THE ORGANIZATION MAKES ITS FORM 990 AVAILABLE FOR PUBLIC INSPECTION AS REQUIRED UNDER SECTION 6104 OF THE INTERNAL REVENUE CODE. it is posted on guidestar.org and other similar types of websites. In addition, the Form 990 as well as the financial statements and governing documents are available upon written request at 158 East 35th street, new york, ny 10016 or by calling the organization directly at (212)889-5500.”

“The organization follows the policies of its' parent company, postgraduate center for mental health, but has not formally adopted them as its' own policies.”

“The organization follows the policies of its' parent company, postgraduate center for mental health, but has not formally adopted them as its' own policies.”

“PCMH Shakespeare Housing development Fund Corporation's Board assumes responsibility for the oversight of the audit of its financial statements and selection of its independent auditor. The policy for selection and oversight of the independent auditors has not changed since last year.”

“Explanation for prior period adjustment of $119,110: To adjust opening balances for In-Kind repayment for FYE 2016.”

“Election Pursuant to Internal Revenue Code Section 168(H)(6)(F) Election to be treated as a taxable entity Reference is made to PCMH SHAKESPEARE AVENUE, L.P., a New York limited partnership (the "Partnership"), of which PCMH SHAKESPEARE AVENUE GP, INC., a New York corporation (the "General Partner") is the general partner and BFIM STRATEGIC HOUSING FUND I, LIMITED PARTNERSHIP, a Massachusetts limited partnership (the "Investor Limited Partner") the limited partner (the Limited Partner"). PCMH SHAKESPEARE AVENUE HOUSING DEVELOPMENT FUND CORPORATION, a New York not-for-profit corporation (the "Exempt Organization") owns 100% of the issued and outstanding shares of the General Partner. We are the accountants for the General Partner and the Exempt Organization. Section 168(h) of the Internal Revenue Code of 1986, as amended (the "Code") provides that where a "tax-exempt controlled entity" is a partner in a partnership, and the allocation of certain tax items to that partner is not a "qualified allocation" (as that term is defined in Section 168(h)(6)(B) of the Code), then a "proportionate share" of the Partnership's property, equal to that partner's highest share in the partnership's income or gain of the Partnership, is considered "tax exempt use property and must be depreciated using the alternative depreciation system" provided by Section 168(g) of the Code. However, no portion of the Partnership's property will be treated as tax-exempt use property and depreciated using the alternative depreciation system if the tax-exempt controlled entity makes an election (the "Section 168(h)(6) Election") under Section 168(h)(6)(F)(ii) to not be treated as a tax-exempt entity for purposes of Sections 168(h)(5) and (6) of the Code. We understand that it is material to the Limited Partner that the Partnership's property not be depreciated using the alternative depreciation system, and that the Limited Partner are making their investment in reliance upon the covenant of the General Partner and the Exempt Organizations to assure that a proper and timely Section 168(h)(6) Election is made. As the accountants for the General Partner and the Exempt Organization, we acknowledge that the General Partner and Limited Partner intend that the Section 168(h)(6) Election be made on a timely basis. We understand that: 1. The Section 168(h)(6) Election must be made by the due date (including extensions) of the tax return for the first tax year that the election applies. We expect this due date (before extensions) to be March 15, 2018, which is March 15 for the year following the year in which all or any portion of the Partnership's housing project is placed in service. Notwithstanding the foregoing, the General Partner is required to make the Section 168(h)(6) Election as a condition to payment of the Fifth Installment of Capital Contributions by the Investor Limited Partner. In order to satisfy this condition, the General Partner will need to make the Section 168(h)(6) Election in conjunction with the filing of its 2017 tax return. 2. The Section 168(h)(6) Election must be attached to the General Partner's tax return, with a copy attached to the tax return of the Exempt Organization. 3. The Section 168(h)(6) Election shall: a. contain the name, address and taxpayer identification number of the General Partner, b. identify the election as a Section 168(h)(6) Election, c. state that the election applies to all of the General Partner's property, and that the election applies to the taxable year that the Partnership's property is placed in service and all subsequent years, d. state that the General Partner is entitled to make the election because it is a tax exempt controlled entity that is timely filing the election, and e. include such other information and comply with such other requirements as may be determined by the Internal Revenue Service or the United States Treasury Department. Executed this 20th day of April, 2017.”