Pcmh Washington Avenue Housing Development Fund Corporation

ELECTION PURSUANT TO INTERNAL REVENUE CODE SECTION 168(H)(6)(F):

“Election not to be treated as a tax-exempt entity taxpayer: pcmh washington avenue gp inc. Ein:83-3554450 the taxpayer, a for-profit subsidiary of nyc partnership pcmh washington avenue lp (ein: 83-3590983) a not-for-profit organization, hereby elects under internal revenue code section 168(h)(6)(f)(ii) as a tax exempt controlled entity: (1) not to be treated as a tax-exempt entity for purposes of internal revenue code sections 168(h)(5) and (6), and (2) to treat any gain recognized by its tax-exempt parent on any disposition of an interest in it (and to treat any dividends or interest received or accrued by its tax-exempt parent from it) as unrelated business taxable income under code section 511. This election shall apply to all of the company's property for the year that property is placed in service and all subsequent years. The company is entitled to make this election because it is a tax-exempt controlled entity that is timely filing the election.”