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• 01. Who is an investor? Do contributors (i.e., gifts or transfers without expectation of a return or profit) qualify for the credit? Do investors who are non-owners of child-care facilities qualify for the credit?

• 02. Do investments in non-profit facilities qualify for the credit?

• 03. Is a loan considered an investment?

• 04. Are the tax benefits under § 5219-Q considered returns on investment?

• 05. Should only expenditures incurred above and beyond minimum licensing standards qualify for the ITC?

• 06. Once salaries or other ongoing expenditures are certified for the credit, do they indefinitely qualify under the "working towards the goal of" quality child-care standards?

• 07. Do rental costs qualify for the credit? (Note: The same issues raised relative to salaries also apply to rental costs.)

• 08. Do financial institutions taxed under § 5206 qualify for the credit? Do flow-through entities (if so, what credit base is used)? Do insurance companies qualify?