(A TheoPRO Strategic Partner)
When Should You Have A File Review Completed?
100% File Reviews
Tax credits are at the greatest risk early in the 15-year compliance period and at times of“transition” e.g. sales and other transfers of ownership, replacement of GP’s, management changes, etc. We recommend the following protocol to complete audits of 100% of lease files during these times when the credits are at highest risk.
Partial File Reviews
With the changes to the Code included in HR3221, the requirement for annual recertifications is greatly reduced. However, many states are placing strict additional requirements to exempt properties from annual recertifications. To ensure that “stabilized”properties remain in compliance, we recommend partial file audits (the greater of 10% or 10 files) based on the following protocol: