Understanding BC's History Of Rent Controls And Tax Policy To Improve .

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April 2019Understanding BC's History of RentControls and Tax Policy To ImproveToday's Rental Housing CrisisLandlordBC1210 - 1095 West Pender St.Vancouver, BC V6E 2M6www.landlordbc.caSum quas pari uirepudi culparum rujoagaposseque optate que dinvolupis minusa s

2 /Understanding BC's History of Rent Controls and Tax Policy To Improve Today's Rental Housing CrisisLandlordBC is a non-profit associationrepresenting owners and managersof rental housing in British Columbia.As the industry leader, LandlordBC’smandate is to advocate for thebetterment of the rental housingindustry for the good of landlordsand tenants alike. LandlordBC iscommitted to maintaining a proactiveand positive collaborative relationshipwith government, media and allstakeholders to promote a balancedand healthy rental housing market inBritish Columbia. The association alsoprovides education and support tolandlords across the province includingeducational events, networkinggatherings, webinars, publications, andprograms like the Landlord Registry .Date Released: April 2019 2019 LandlordBCAll rights reserved. The material may not be reproduced or distributed, in whole or in part,without the prior written permission of LandlordBC. Requests for permission to reproduce anypart of this publication for academic, professional, or commercial purposes should be sent to:dhutniak@landlordbc.ca

Understanding BC's History of Rent Controls and Tax Policy To Improve Today's Rental Housing Crisis/ 3EXECUTIVE SUMMARYIt is generally agreed that today, British Columbia, and in particular theprovince’s large urban centres, is challenged by a rental housing supply andunaffordability crisis. Understanding that approximately one-third of BritishColumbians live in rental housing, the magnitude of this current rental housingcrisis is widespread and negatively impacts the province’s entire economy.The purpose of this report is to analyze the history of rent controls and tax policyto understand how the province came to be challenged by the rental housingcrisis now impacting British Columbia, and what lessons can be learned fromthis history to improve the rental housing environment today and into the futurefor the benefit of British Columbians.AnalysisWhile it is widely claimed that the vastmajority of purpose-built rental housing wasconstructed due to tax benefits prior to themid-1970s, this paper demonstrates thatthese benefits of deferred taxation were offar less value than believed. What has beenoverlooked is that at the same time that theFederal government implemented tax reform,the regulatory environment in which landlordsoperated drastically changed. Rent control andstringent rent regulations were introduced inthe mid-1970s, permanently altering investors’view of the multi-family rental buildingbusiness. In addition, the Strata Titles Act of1966 and 1974 gave multi-family residentialdevelopers a lucrative alternative: buildingcondominiums.While deferred taxation offered benefits tothe multi-family residential developer prior to1972, we calculate that the present value ofthese benefits was less than 7.5% of a woodframed building’s value and less than 2.5% of ahigh-rise building’s value. In contrast, today’slower interest rates offer far more benefitsto the multi-family residential landlord. Inthe 1960s, a typical mortgage rate was about7.5% and in the late 1970s (at the height of theMultiple Unit Residential Building program) anaverage mortgage rate was about 10.5%. Wecalculate the present value of today’s lowermortgage rate (roughly 3.5%) is a least 12%and as much as 62% of a building’s value. Yet,purpose-built rental housing constructionstill lags tremendously behind condominiumconstruction.Research shows the tax benefits of the wellknown MURB program were capitalized intoland values and, as such, the returns on theseinvestments were no different than non-MURBprojects. As a result, the tax benefits of theprogram bestowed windfall gains to existingland owners rather than made purpose-builtrental housing more attractive. The successof this program hinged critically upon thedistinction that virtually all MURB projectsThe Strata Titles Actof 1966 and 1974 gavemulti-family residentialdevelopers a lucrativealternative: buildingcondominiums.

4 /Understanding BC's History of Rent Controls and Tax Policy To Improve Today's Rental Housing CrisisThe tax benefitsof the MURBprogram bestowedwindfall gains toexisting land ownersrather than madepurpose-built rentalhousing moreattractive.

Understanding BC's History of Rent Controls and Tax Policy To Improve Today's Rental Housing Crisis/ 5were strata titled, and not purpose-built rental,enabling investors to sell the units of suchprojects into the ownership market to reaptheir returns. The rental industry was freefrom rent control and restrictive regulationsbefore the 1970s. Once rent controls andrestrictive regulations were introduced into therental market, investors viewed condominiumdevelopment as more attractive as it was freeof price controls. In fact, condominium priceswere supported by a Federal capital gainstax exemption on principle residences. As aresult of these factors, purpose-built rentalconstruction plummeted in comparison tocondominiums.ConclusionRent controls are incredibly destructive to therental housing industry for potential rentaldevelopers, landlords, and renters. Ninetyfive percent of economists believe that rentcontrols have a negative effect on the qualityand quantity of housing in the cities thathave used them. Economic studies have alsoEconomic studies havealso demonstrated thatrent controls have failedto prevent increasedrents and rental housingunaffordability.demonstrated that rent controls have failedto prevent increased rents and rental housingunaffordability.RecommendationsTo create the necessary supply of rentalhousing to meet the existing and growingdemand across British Columbia, withouttaxpayer subsidies, the following policies arerequired:1. Immediately exempt newly built marketpurpose-built rental buildings from all rentcontrols. The exemption would only applyto newly built market purpose-built rentalbuildings constructed after this proposedexemption policy was implemented byGovernment. Furthermore, it will only applyto those buildings which will be maintainedas secure purpose-built rental housinginto perpetuity. The exemption would beguaranteed for a minimum of 20 years;2. Equalization of land values betweencondominium and rental development bygranting zoning variances for market rentaldevelopments including increased density,reduced parking requirements, reducedamenity space, reduced unit sizes, and nocommunity amenity contributions; and,3. Removal of the tax disadvantages to rentalrelative to condominium development, andin particular, the Federal GST charged on a“self-supply” of new rental housing.

6 /Understanding BC's History of Rent Controls and Tax Policy To Improve Today's Rental Housing CrisisUNDERSTANDING BC’SHISTORY OF RENTCONTROLS AND TAXPOLICYTO IMPROVE TODAY’SRENTAL HOUSING CRISISIt has been widely claimed that favourable tax incentives resulted in the vastmajority of the market rental housing development in Metro Vancouver duringthe 1950s, 60s, and 70s. The commonly held belief is that after such policies werewithdrawn, rental housing development suffered and that has caused a marketrental housing shortage. Many research papers on taxation policy have arguedthat tax incentives were the main reason for the rental housing constructionboom of past decades and their elimination the reason for the dearth of rentalhousing supply since.And there is ample evidence of the mediaciting various commentators arguing that taxmeasures produced most of the affordablerental housing found around Vancouver today.While our industry is very much in favourof efficient tax proposals for market rentalhousing construction, what these researchpapers and commentators ignore whenanalyzing the stunning falloff in rentalapartment supply is changes to the regulatoryenvironment. Specifically, rent control.Rent control was introduced in BritishColumbia, and across Canada, in the mid1970s and vastly hindered the ability oflandlords to recover their cost increases just atthe time inflation was spiking. It was a massivechange to the business of rental housingand was met with vehement oppositionby rental housing providers at the time. Inaddition, in 1966, the Provincial governmenthad introduced the ability for developers tosell their apartment units as condominiumsto end owner-users. This new legislation,modified and updated in 1974, gave real estatedevelopers a lucrative alternative to rentalhousing construction that was free from pricecontrols. We will show that these two changesto the business environment for housing hada massive impact and were predominant in

Understanding BC's History of Rent Controls and Tax Policy To Improve Today's Rental Housing Crisis/ 7effect rather than changes to taxation policy,which was secondary and relatively minimal inimpact.This paper summarizes the history of taxationpolicy, rent control and regulation of the rentalhousing industry in British Columbia (see theAppendix for a simplified timeline). It offers anexamination of the policies that led to rentalhousing construction in Metro Vancouver’spast and the unfavourable policies that haveresulted in its diminished new supply.The tax benefits offered before 1972, andduring 1974 to 1981 with the Multiple UnitResidential Building (MURB) program,were too modest to be responsible for thesubstantial rental construction during the1950s, 60s, and 70s and its subsequent dropoff until today. Rather, the absence of rentcontrol and prohibitive regulations wereWhile our industryis very much infavour of efficient taxproposals for marketrental housingconstruction, whatthese research papersand commentatorstend to ignorewhen analyzing thestunning falloff inrental apartmentsupply is changesto the regulatoryenvironment.Specifically, rentcontrol.much more responsible for the high levelof rental housing construction during thatperiod. The introduction of stringent rentcontrol and regulations in the mid-1970screated a detrimental and uncertain businessenvironment for rental housing providers at theexact time real estate developers were given amore viable and business friendly alternative:building condominiums. As a result, after themid-1970s the supply of new rental housingdiminished drastically and condominiumconstruction flourished. The negatives fromrent control and subsequent tax policies biasedtoward home ownership, and thus favoringcondominium development, far outweighedany benefits from deferred taxation to rentaldevelopers.

8 /Understanding BC's History of Rent Controls and Tax Policy To Improve Today's Rental Housing CrisisThe negatives fromrent control andsubsequent taxpolicies biasedtoward homeownership, andthus favoringcondominiumdevelopment, faroutweighed anybenefits fromdeferred taxation torental developers.

Understanding BC's History of Rent Controls and Tax Policy To Improve Today's Rental Housing Crisis/ 9Changes to Purpose Built RentalSupply, Households, Rents, andthe Secondary MarketPurpose-built rental development averagedapproximately 2,000 units per year from 1951to 1971 in City of Vancouver (see Chart 1). The20-year period from 1951 to 1971 resulted inthe rental housing stock more than doublingfrom 37,445 to 78,985 units. Between 1958 and1973, 35,019 rental units were added citywidein Vancouver, which by 2010 comprise 68% ofthe rental housing stock. In contrast, in the 36years subsequent to 1973, only 7,121 units havebeen added to the rental housing pool until2010, or 13.7% of the total rental pool1.Also since 1973, Vancouver's population hasincreased from approximately 419,000 in1973 to approximately 631,000 today. Thatmeans only 1 new unit of rental housing wasproduced for every 30 new residents over the1973-2016 period.Chart 1 demonstrates that rental housingconstruction generally kept pace with rentalhousehold growth from the 1950s throughthe 1970s. Subsequently, rental housingconstruction fell off dramatically while rentalhouseholds continued to grow.1City of Vancouver Rental Housing Strategy Research andPolicy Development, Synthesis Report, McClanaghan &Associates, August 2010, pages 30-32

10 /Understanding BC's History of Rent Controls and Tax Policy To Improve Today's Rental Housing CrisisIn the period before rent control wasintroduced in British Columbia, rentalapartments throughout Canada wereconstructed at roughly the same rate as homesfor the ownership market. Chart 2 demonstratesthat between 1963 and 1968, rental apartmentsaccounted for nearly half of all Canadianhousing starts2.2Ibid, page 35Given that thesepolicies arecredited withthe creation ofthousands of unitsof rental housingbefore the mid1970s, it makessense to examinethem to see whatlevel of financialbenefit theyprovided.Today, the vast majority of apartment unitsare constructed as condominiums rather thanpurpose-built rentals. Chart 3 shows housingcompletions between 1990 and 2017. It’s clearthat in Vancouver rental apartments representa fraction (roughly 21%) of condominiumcompletions since the 1990s. In addition,that percentage has been higher in recent

Understanding BC's History of Rent Controls and Tax Policy To Improve Today's Rental Housing Crisis/ 11years due to changes in zoning bylaws and regulations at the City of Vancouver (and othermunicipalities) to encourage market rental housing development.The increase in rental supply since the 1970s has mainly come from secondary suites, noneof which are restricted as purpose-built rental units, and which therefore put tenants at risk ofdisplacement when the homeowner sells or needs to reclaim the space for family use. The 2016Statistics Canada Census reports that we have 960,895 private households in Metro Vancouver3.Of these households, 303,020 are market renter households or 31.5% of total households4. Table1 and Chart 4 break down these rental households by type. CMHC’s 2016 Rental Market Reportindicates there are 107,867 purpose built rental units in Metro Vancouver5. As a result, 195,153rental households are in the secondary market or 64% of total rental households. Consequently,by 2016, the vast majority of the rental households were living in secondary rental units that arenot secured in tenure6.3Statistics Canada Census Profile, 2016 Census4Ibid5CMHC Rental Market Report, Vancouver CMA, 2016The Statistics Canada Census, 2016 indicated that 32,380 single detached houses were rented as full homes. We believe thisdata may be subject to a reporting bias because it is likely that these homes are split into units and the units are individuallyrented out as suites. If that were true, then the number of illegal suites rented out in the secondary market would be two orthree times this figure in addition to the 62,045 suited SDH units. It is also worth noting that CMHC estimates the number ofrented condominiums as 58,089 units in 2016 (from the CMHC Housing Portal) for Metro Vancouver.6Chart 5 demonstrates that rental growth rates have accelerated while supply stagnates:

12 /Understanding BC's History of Rent Controls and Tax Policy To Improve Today's Rental Housing Crisis"Consequently, by 2016,the vast majority of therental households wereliving in secondaryrental units that are notsecured in tenure."The data clearly demonstrates that newpurpose-built rental supply fell off after the1970s. Since that time rental unit growth hasbeen dominated by the secondary marketwhich is not actually secured as market rentalhousing. The question is: Why did purposebuilt rental housing construction fall off sodramatically? Was it tax incentives or rentcontrol and the regulatory environment orsome combination of these factors whichcaused investors to eschew building securedpurpose built rental housing?A Brief Overview of HistoricalTaxation Policies for MarketRental HousingMarket rental building operators are able todeduct depreciation claims against income fortax purposes. Prior to 1949, a straight-line basisof depreciation was generally used againstincome over the useful life of the property. TheCapital Cost Allowance (CCA) system becameeffective on January 1, 1949 and allowed foraccelerated depreciation such that the amountclaimed against income is higher in the earlieryears of a project and declines over the lateryears7.Prior to 1972, CCA on wood framed buildingswas allowed at 10% and on all other buildingsat 5%. In addition, excess CCA was availableto reduce non-rental taxable income. This isthe so-called “flow-through” provision. Nocapital gains taxes existed. There were alsosoft cost write-offs available for new housinginvestment. Further, recaptured CCA wasdeferred if a property in the same class wasacquired in the same tax year as the year ofdisposition for an amount at least equal to theproceeds of the sale (the “rollover” provision).Otherwise, all of the CCA claimed on abuilding is subject to recapture as income (atthe full income tax rate) when the building issold8.provisions were eliminated and investors wereno longer able to reduce non-rental taxableincome with CCA deductions from rentalproperty. Capital gains tax was introduced at a50% inclusion rate for all investments includingreal estate. However, capital gains tax wasexempted for a principal residence providinga massive tax advantage for homebuyers and,therefore, condominium developers that stillexists today. The CCA rollover provision wasalso eliminated9.From 1974-81, a tax program was offeredcalled the Multiple Unit Residential BuildingProgram (MURB). The main feature of thisprogram is that it offered the “flow-through”provision so that investors could offset nonrental income with CCA deductions10. By 1978the allowable CCA was reduced to 5% for allbuildings11.The policies most frequently credited forcreating rental housing are the acceleratedCCA provisions as well as the flow-throughprovisions such that investors could offsetnon-rental taxable income with CCAdeductions. After 1972, the flow-throughpolicy came to an end until the MURB programin 1974 re-instated them for MURB projects.1998, page 10-119After the tax reforms of 1972, the flow-through7The Capital Cost Allowance System, Israel Mida andKathleen Stewart, 1995, page 1246-1247Economic Impact of Federal Tax Legislation on the RentalHousing Market in Canada, Clayton Research, November8Ibid, page 10-11An Analysis of the Effects of MURB Legislation onVancouver’s Rental Housing Market, Anne Patricia Wicks,198210Economic Impact of Federal Tax Legislation on the RentalHousing Market in Canada, Clayton Research, November1998, page 10-1111

Understanding BC's History of Rent Controls and Tax Policy To Improve Today's Rental Housing Crisis/ 13Analyzing Changes to Tax PolicyTax Policy Prior to 1972The most important benefit of the tax structureprior to 1972 was a CCA rate of 10% on woodframed buildings and 5% on high rise buildingsas well as the flow-through provision for highincome professionals, meaning losses at arental building could be used to reduce taxableincome earned through professional fees. Thecurrent CCA rate on all buildings is 4% and theflow through for high income professionals nolonger exists.Given that these policies are credited withthe creation of thousands of units of rentalhousing before the mid-1970s, it makessense to examine them to see what level offinancial benefit they provided. In Table 212,we calculate the present value13 of the higherCCA rates prior to 1972 on a 15 million newlyconstructed rental property to determine howsignificant the tax advantages were at thattime.The CCA tax deduction representsdepreciation on the structural components ofa building. These are real expenses which thetax laws permit based upon an accelerateddeclining schedule. When the CCA rate ishigher, real estate companies can claim thetax deduction faster rather than slower. Thathas a cash flow benefit in the earlier years ofan investment. The tax deduction is receivedfaster and, therefore, from a present valuebasis, is beneficial to investors. The benefit istempered upon sale of an asset when the CCAdeductions for tax purposes are recapturedif the asset is sold for a price higher than theundepreciated cost basis at the time (and thatTable 2 assumptions: 45% marginal tax rate; full recaptureupon sale (building sold at higher than original cost); 3.25%discount rate (current 5-year CMHC multi-family residentialmortgage rate, excluding cost of mortgage insurance); and,demolition in year 50. Discounted at 7.5%, the values in thetable from top down are 1,260,739, 1,087,756, 504,813, 341,407, 282,173, 128,807; and, 8.40%, 7.25%, 3.37%,2.28%, 1.88%, 0.86%1213At today’s estimated mortgage rate of 3.25%.The question is: Whydid purpose built rentalhousing constructionfall off so dramatically?

14 /Understanding BC's History of Rent Controls and Tax Policy To Improve Today's Rental Housing Crisisis frequently the case). In other words, the taxbenefit typically is a deferral of taxes to lateryears despite the fact that depreciation is avery real expense. It is almost always the landvalue that has appreciated on a profitable salerather than the building’s value. This assumes,of course, that prior to 1972, the rolloverprovision was not used. In other words, theinvestor did not repurchase another rentalbuilding within the same tax year (the rolloverprovision is essentially the “Never sell” scenarioin Table 2).On a wood-framed building, the benefit isless than 7.25% of the building value if thebuilding is never sold and recapture never paid.However, the market for apartment buildingsis very robust and currently represents annualtransaction of almost 3bn per year14. It issomewhat rare for an investor to hold abuilding forever. If a wood-framed buildingwas sold within 10 years, then the tax benefitfrom a 10% CCA rate was less than 2% of thebuilding’s value. It is important to note that thegovernment reclaims all of the depreciationlosses and the tax associated with the resultingincome at the time a building is sold.buildings that were only allowed a 5% CCA rate(compared to 10% for wood-framed buildingsprior to 1972 and 4% today). The tax benefitwas marginal in all cases.Given that high-rise construction did notbenefit nearly as much from these taxadvantages, we address the question ofwhether or not high-rise development wascommon prior to 1978 when the CCA ratewas reduced to 5% for all buildings. We havedata on Metro Vancouver purpose built rentalhousing stock, excluding Vancouver, from aMay 2012 Coriolis Consulting report preparedfor Metro Vancouver15. The data in that reportdemonstrates that within Metro Vancouver,but outside the City of Vancouver, the existingrental inventory as of 2012 includes 47,635units built up to 1979. Of this inventory, 31%was high-rise and the percentage was likelymuch higher in the City of Vancouver. As aresult, the lower 5% CCA rate did not seem toslow development of these buildings.Additionally, these CCA rates were viewed asaccurate relative to depreciation timing whenthey were set. These were not viewed as a taxincentive.Table 2 also shows tax benefits on high rises14Goodman Report, 2018 Mid-Year Greater Vancouver RentalApartment Review, July 201815Metro Vancouver Purpose-Built Rental Housing: Inventoryand Risk Analysis, Coriolis Consulting Corp., May 8 2012

Understanding BC's History of Rent Controls and Tax Policy To Improve Today's Rental Housing Crisis/ 15An important 1998 study indicated that“Until the mid-1970s the private marketproduced substantial quantities of privaterented apartments without a visible explicitsubsidy for rented housing. There was no rentcontrol and there was growing demand forrented accommodation from newly forminghouseholds, including immigrants fromoverseas”16. The study did note, however, thatCCA provisions and soft cost deductions werefavourable at the time.Lastly, the flow through provision seemsof marginal value given that real estatecompanies today can use CCA on new rentaldevelopments to offset income from otherrental properties in their portfolio, giving themthe same advantages enjoyed by professionalswith high incomes prior to 1972. Yet, thesesame companies stopped developing rentalbuildings after the 1970s for their own portfolioas well.Multiple Unit Residential BuildingProgramWhile the flow through provisions cameto an end in 1972, the MURB program wasintroduced in 1974 and was effective through1979 and then from late 1980 through1981. We know that in the two decades thatNeth. J. of Housing and the Built Environment, Vol. 13(1998) No. 3, Tony Crook, page 340preceded 1972, roughly 2,000 purpose builtrental units per year were constructed by theprivate market in Vancouver. Chart 6 showsthat the MURB program succeeded in creatingmulti-family housing.However, while the MURB program allowedfor the flow-through provision, the CCA ratewas reduced to 5% for all buildings in 1978during and after which there was significantprivate rental housing built. As we have seen,the 5% CCA rates was of somewhat marginalbenefit compared to today’s 4% rate. Also,the CCA rollover provision was not reinstated for MURB buildings. Lastly, a veryinformative 1982 study by a U.B.C. Master’sstudent hypothesized that the “real effect ofthe program was to create windfall gains forexisting owners of multiple family zoned landat the time the legislation was passed .thattax shelter benefits associated with MURBproperties will be fully capitalized into thevalue of such properties, thus preventingMURB investors from earning rates of returnsuperior to those earned by owners ofcomparable non-MURB properties.”17 Thestudy found that the average after tax returnsearned for MURB and non-MURB propertyinvestments were essentially equivalent at12.8% for MURB properties and 13.2% for nonMURB properties. It concluded, therefore,1617An Analysis of the Effects of MURB Legislation on

While MURBs didincrease the supply ofhousing in an uncertainenvironment dictatedby increasing rentcontrol and regulations,this housing wasn’tactually purpose-builtrental housing at all.

Understanding BC's History of Rent Controls and Tax Policy To Improve Today's Rental Housing Crisis/ 17The “success”of the MURBprogram dependedheavily on thecritical legalnuance that theywere really stratacondominiumsthat could beindividually soldinto the ownershipmarket at anytime.that “future tax shelter benefits associatedwith MURB properties are capitalized into themarket values of completed MURB buildingsand that MURB investors do not earn rates ofreturn superior to those of investors in nonMURB apartment properties these results donot support the widely made argument thatadverse tax revisions (such as reduction in taxshelter benefits) cause inferior ex ante rates ofreturn in real estate investment. In competitivecapital markets, equilibrium comparativereturns among alternative investments arenot determined by Government subsidiesor differential tax treatments .The only waygovernment programs effect differentialreturns is through any investment risk createdby having a fluctuating or uncertain tax orsubsidy”18.While MURBs did increase the supply ofhousing in an uncertain environment dictatedby increasing rent control and regulations,this housing wasn’t actually purpose-builtVancouver’s Rental Housing Market, Anne Patricia Wicks,1982, page ii18Ibid at page 65rental housing at all. Virtually all MURBs werestrata titled creating a massive distinctionfrom secured purpose-built rental housingstock19. As has been noted in a 1998 study, “Toensure that their investments could be realized,these small-scale individual landlords neededto acquire dwellings that could be easily soldinto owner occupation. Apartment dwellingswere much less attractive to these landlordsthan newly constructed condominiums. Thiswas because apartments would be less easy todispose of then condominiums and becauseof the impact that rent regulation had on largeapartment blocks.”20As a result, the “success” of the MURB programdepended heavily on the critical legal nuancethat they were really strata condominiums thatcould be individually sold into the ownershipmarket at any time.19Rent Control and Decontrol in British Columbia: A CaseStudy of the Vancouver Rental Market, 1974 to 1989, Celia C.Lazzarin, page 13720 Neth. J. of Housing and the Built Environment, Vol. 13(1998) No. 3, Tony Crook, page 336

18 /Understanding BC's History of Rent Controls and Tax Policy To Improve Today's Rental Housing CrisisChanges in Interest Ratesratio of up to 80%22.While tax deductions from CCA are animportant and relevant expense, interestrates have fallen dramatically since the 1960sand should offer a far greater incentive fordevelopers to build rental than the CCAprovisions. Table 321 compares the present valuebenefit of today’s lower interest rates on a 15million property compared to the mid-1960sand to 1978 when MURB construction was at itsheight. We assume this 15 million property hasa 11.25 million mortgage which is a reasonableloan to cost ratio of 75%.Yet these lower interest rates have not beenenough incentive to encourage a significantlevel of purpose-built rental housingdevelopment and new supply is certainly nothigh enough to offset demand. While it is highlylikely that these lower interest rates have beencapitalized into land values, recall that researchhas demonstrated the same was true for thehigher CCA rates and other tax benefits fromrental development prior to 1972.We estimate that the benefit of today’s lowerinterest rates is at least 7.8% and as much as40% of a building’s value. Comparing the resultswith those in Table 2 demonstrates that today’slower interest rates are at least as beneficial asCCA deductions prior to 1972 tax reform. Thebenefits of today’s lower interest rates would beeven

withdrawn, rental housing development suffered and that has caused a market rental housing shortage. Many research papers on taxation policy have argued that tax incentives were the main reason for the rental housing construction boom of past decades and their elimination the reason for the dearth of rental housing supply since. UNDERSTANDING .

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