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LIHTC Compliance · IRC §42 Timeline · Free

Every deadline. Mapped to your deal.

From carryover to Year 15, one missed §42 date can mean credit reduction, recapture, or a forfeited allocation. Enter your dates once — see what’s coming, what’s critical, and what’s already behind you, on a single timeline.

Your project

Tell the tracker about your deal

Name your deal to save it to your dashboard.
Year credits were allocated by the state HFA.
Date on the HFA carryover allocation letter.
Date the building actually entered (or will enter) service.
Owners may elect to defer the start of the 10-year credit period by one year.

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◔ Your next hard deadline
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Full §42 timeline Past Coming Critical

Statutory basis: IRC §42(h)(1)(E)(i) placed-in-service deadline; §42(h)(1)(E)(ii) 10% test; §42(f)(1) credit period; §42(i)(1) 15-year compliance period; §42(h)(6) extended-use period. State QAPs may impose additional deadlines.

Why it matters

The clock starts at allocation — and it doesn’t stop.

From the moment a state HFA awards credits, a LIHTC project is on a fixed sequence of statutory deadlines. Miss one and the consequences are real: credit reduction, recapture, or — for the two hard deadlines — a fully forfeited allocation. This tracker lays the whole sequence against today’s date so the next thing you owe is never a surprise.

The sequence

Seven dates that decide whether the credits survive.

  1. Carryover allocationState HFA awards credits by Dec 31. Starts the 2-year clock to placed-in-service and the 1-year clock for the 10% test.
  2. 10% test — §42(h)(1)(E)Within one year of carryover, the project must have incurred ≥10% of reasonably expected basis. Fail it and the allocation is forfeited.
  3. Placed-in-service deadline — §42(h)(1)(E)(i)By Dec 31 of the 2nd year after the allocation year. Missing it without an approved extension forfeits all credits.
  4. Form 8609 filingIssued by the HFA after cost certification; filed with the owner’s return for the first credit year.
  5. 10-year credit period — §42(f)(1)Annual credits flow Years 1–10 from PIS (or the year after, if elected).
  6. 15-year compliance period — §42(i)(1)Affordability and compliance continue through Year 15, even though credits stop after Year 10.
  7. Year 15 → Extended-Use Period — §42(h)(6)Qualified-Contract window opens after Year 14; the LURA continues for a minimum of 15 more years.
Questions

Before you rely on a date.

What happens if I miss the PIS deadline?
Credits are forfeited unless the project qualifies for relief. Rev. Proc. 2014-49 lets state HFAs grant a PIS extension for projects in federally declared major-disaster areas — the extended deadline is Dec 31 of the year following the standard 2-year carryover period (the third year after the allocation year). Separate IRS notices (e.g., Notice 2022-52) have provided COVID-related relief on similar terms. There is no statutory “good cause” PIS-extension mechanism in §42. Beyond available relief, the allocation reverts to the state’s national pool.
Can I defer the start of the 10-year credit period?
Yes. Under §42(f)(1)(B) the owner may elect to start the 10-year credit period in the year after PIS. This is common when a building is placed in service late in the year and rental income wasn’t material — pushing Year 1 to the next year captures a full year of credits.
When exactly is Form 8609 due?
The state HFA issues Form 8609 after cost certification. The owner files it once — with the federal return for the first year the credit is claimed. For each year of the 15-year compliance period the owner instead files Form 8609-A with the annual return. Practically, both track the owner’s tax-filing deadline (typically March 15 for partnerships, with extensions).

For informational purposes only — not legal, tax, or accounting advice. §42 deadlines interact with state QAP requirements and IRS guidance that change over time. Confirm every date with your HFA, counsel, and tax advisor before relying on it for a transaction.