Change of Year End for Profit Motivated Multifamily Project

Information on changes to year-end can be found here (pages 26-27): https://www.hud.gov/sites/dfiles/PIH/documents/finl_memo_2004_1a.pdf

VIII. Changes in the Fiscal Year End

Profit-motivated and limited dividend owning entities must submit requests to change their fiscal year end to the Internal Revenue Service (IRS) on Form 1128 – “Application To Adopt, Change, or Retain a Tax Year.” Upon receipt of this request, the IRS issues a “Private Letter Ruling” indicating its decision.

Nonprofit or tax-exempt entities under section 501(c) are not required to submit Form 1128 to change the fiscal year end, unless the owning entity has changed its tax year at any time within the last 10 years. This procedure is called “Expeditious Approval.” The IRS permits nonprofit entities to change their fiscal year end without prior approval if they meet the above requirement.

PMs must not change the fiscal year end information in REMS for profit-motivated and limited-dividend entities until they receive a copy of IRS’s “Private Letter Ruling.” If the property is owned by a nonprofit entity, the owner must submit a letter to the local Hub/Program Center certifying that the fiscal year end has not changed within ten years. If this letter is not received, the PM must not change the fiscal year end date in REMS.

Fiscal year end dates apply to owning entities, not to projects. In cases where the owning entity has multiple properties, the PM must verify that the ownership information and TIN in REMS are the same for those properties before changing the fiscal year end date.

Within 30 days of approving a fiscal year end change, the PM must inform the REAC Technical Assistance Center (TAC) (888-245-4860) of a change in fiscal year end. Changing the “Fiscal Year End” in REMS triggers overdue tracking. FASS-MF must be informed of these changes to override the overdue tracking to prevent referral of the owner to the DEC.

Example: if the fiscal year end is 12/31 and is being changed to 06/30 during calendar year 2004, overdue tracking will look back twelve months for the 06/30/2003 AFS submission. The owner’s coordinator will receive a notice indicating that the 06/30/2003 AFS is overdue. Contacting the TAC within 30 days of the change allows REAC to override overdue tracking and prevents an unnecessary referral to the DEC.

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