Key Takeaways
- New York City raises the Form TC309 audit threshold for rent-producing properties to $5.4 million in assessed value for the 2026/27 tax year.
- The updated Form TC309 clarifies that the $5.4 million threshold applies per individual tax lot — not to consolidated multi-lot properties.
- Property owners near the new threshold should assess upcoming valuations to determine if an independent CPA audit and Form TC309 filing will be required.
The NYC Tax Commission (the Commission) requires certain rent-producing properties that exceed a specified assessed value threshold to submit Form TC309, an independent CPA certification including an auditor’s report, when a property tax appeal is filed. The form must be filed together with the TC201 Income and Expense Schedule to independently verify reported income and expenses for higher-value rental properties.
For the upcoming 2026/27 tax year, the Commission has increased the tentative actual assessed value threshold that triggers the Form TC309 audit requirement from $5 million to $5.4 million.
What This Means for Property Owners
The increase may help certain properties not have to undergo the audit process, which can add more time and cost before the expected March 24 deadline.
It is also important to note that the revised 2026/27 Form TC309 introduces an additional disclosure relevant to multi-lot and consolidated properties. The form clarifies that the increased assessed value threshold applies individually to each tax lot, rather than to the consolidated assessed value of multiple lots.
Next Steps
For properties approaching the $5.4 million assessed value threshold, owners and advisors should closely review the tentative assessments expected to be released by the Department of Finance on January 15. These assessments will determine whether a TC309 filing is required, triggering the need for an independent CPA audit of the property’s rental income and operating expenses and additional advance planning.
Contact Us
If you have any questions, please contact your PKF O’Connor Davies client service team or:
Samuel E. Botta, CPA
Partner
sbotta@pkfod.com
Nikki Cerchione, CPA
Director
ncerchione@pkfod.com