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C corporation · FL · tax year 2026 · Tampa, FL · contact Peter Lindqvist, VP Finance

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Step 8 of 8

Gap check

Here is what is still missing. Everything else is ready to run.

Seabreeze condos: R&D project narratives not started
Bayshore Medical: tenant improvement allowance split not uploaded
conservative: 450000 of 2026 general business credit carried back to 2025 (39(a)(1)); the refund is claimed after 2026 (Form 1139/1045 or an amended 2025 return): CPA files
moderate: 450000 of 2026 general business credit carried back to 2025 (39(a)(1)); the refund is claimed after 2026 (Form 1139/1045 or an amended 2025 return): CPA files
aggressive: 502977 of 2026 general business credit carried back to 2025 (39(a)(1)); the refund is claimed after 2026 (Form 1139/1045 or an amended 2025 return): CPA files

35 questions for the CPA

Section 179 expensing of qualified real property (179(e)) and building-related personal property property (Harbor Pointe Apartments (180 units)): C corporation lessor: 179 possible on personal property items in residential rental property, limited to business income. Residential building components are not 179(e) property.
energy-efficient building deduction (incl. designer allocation) (Bayshore Medical Office (62,000 sq ft)): Construction began 2023-01-10, on or before 2026-06-30. Needs energy modeling; the deduction reduces basis and must not double count cost seg components. Property is already on 2 returns: energy-efficient building deduction is claimed for the placed-in-service year, so only an amended return within the refund statute works; CPA to confirm.
Completed contract method (completed-contract) for homebuilders and the Shea Homes subdivision-completion position (Seabreeze Condominiums (64 presold units)): completed-contract is not available for the pre-OBBBA condo contracts; it is available only for contracts entered in a tax year beginning after 2025-07-04 (change number 275 cut-off change). Confirm which contracts fall after the cut-off.
Section 41 Research Credit for Builders, Designers and Contractors (with 174A) (Seabreeze Condominiums (64 presold units)): Builder reports genuine design/engineering experimentation not funded by a customer: screen for 41 credit (high risk; 174A and 280C(c) interplay).
Electing real property trade or business (163(j)(7)(B)) vs depreciation system depreciation: the interest-vs-depreciation trade-off: Not a small business: compare today's value of interest deduction gained vs depreciation lost (depreciation system, QIP bonus) before electing RPTOB. OBBBA's restored depreciation add-back to ATI reduces the need.
For a project begun before 2025-01-20 and placed in service in 2025-2026, can any personal property components be treated as separately 'acquired' after 2025-01-19 (component election under Notice 2026-11 sec. 3.05 applies to larger self-constructed property that is itself qualified property)?
Is the taxpayer a small business exempt from inventory cost rules and 163(j) for this year?
For projects straddling 2025-01-19, is the component election or a separate-property argument available for later-installed personal property items?
Should the client elect 40% under bonus depreciation(10) for 2025 (e.g., to use expiring credits/NOLs or smooth income)?
For exempt small builders, which indirect costs still must be capitalized to real property held for sale under 263(a) and basis rules even though inventory cost rules does not apply?
Is the client's GAAP capitalization policy the right starting point for section 471 costs?
Does 460(c)(3) still require interest allocation for small-contractor exempt residential contracts even though inventory cost rules exempts the taxpayer from inventory cost rules?
163(j)(5) excludes inventory cost rules(f)/263(g) interest; 163(j)(10)(D) covers any provision under which interest is required or may be capitalized. Which required-capitalization provisions other than inventory cost rules(f)/263(g) (e.g., 460(c)(3)) fall under (j)(10)? Await guidance.
Is each entity the eligible contractor (owned and had basis during construction)?
Which multifamily buildings meet PW and apprenticeship rules and have Form 7220 support?
Is the rental an active trade or business for 179?
SUV limit for 2025 after OBBBA (IRS guidance removed sec. 2.25 of IRS guidance which contained the SUV figure)?
What counts as 'construction begins' for energy-efficient building deduction(i) (no IRS definition found; physical work vs 5% safe harbor analogies are speculative)?
Does a design-build GC qualify as the 'person primarily responsible for designing' on public projects?
Any exam open on the property?
Was an elect-out or SL election made for any class in the PIS year?
Will Treasury update 1.460-3/-4/-5 for 'residential construction contract'?
For mixed-use buildings, does the 80% test still pass after OBBBA (1.460-3(b)(2)(iv) allocation)?
Would a house-and-lot completion convention with secondary-item severance be the safer default for this client?
Any post-2017 cases or regulations on development-level completion? (none found this session)
Does the builder's GAAP policy capitalize model/sales office or marketing costs into project cost, and how much is on hand at year end?
Is the builder under exam or within the 5-year rule for any inventory cost rules item?
Does any claimed business component survive the 80% substantially-all test with project-level documents?
Are fixed-price contracts funded under Meyer Borgman / Populous facts?
Firm retention policy vs client retention policy
Is any new 2026 163(j) regulation or notice pending post-OBBBA?
Is the client a 'tax shelter' under 448(d)(3) due to loss allocations to limited partners?
Does the client already have an irrevocable RPTOB election from 2018-2024 when ATI was EBIT-based?
Is the client under exam or in Appeals?
Any change made in prior 5 years for the same item?

Current estimate with these gaps: $1,949,453 (moderate, after fees).

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