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DEVELOPER CHECKLIST

Does the project work?

Mark each topic as documented, incomplete, or needing specialist review. Open the explanation when you need it.

01
Location & dates

Confirm official designation and applicable dates.

What to confirm

Keep the tract identifier, official designation evidence, effective date, and intended acquisition date together. Eligibility or nomination alone is not certification. Check rural status separately.

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02
Ownership & acquisition

Identify how the project receives the property.

What to confirm

Document the current owner and ownership tree, then distinguish purchase from contribution. Review any seller relationship, indirect ownership, attribution, existing debt, and transfer consequences with counsel.

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03
Development plan

Define new construction, rehabilitation, or both.

What to confirm

Describe the existing and proposed assets. New construction may use original-use rules; existing buildings may require substantial improvement. Separate new construction is not automatically rehabilitation of the existing building.

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04
Asset classification

Separate qualifying and nonqualifying property.

What to confirm

Classify land, existing buildings, new buildings, and other assets individually. A property contribution does not become a qualifying purchase simply because a new LLC takes title.

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05
Asset tests

Document the project’s 70% test and the fund’s 90% test.

What to confirm

Use a permitted, consistently applied valuation method. Model construction as well as stabilized operations and all other business tests. These are asset tests—not equity-source or ownership percentages.

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06
Entities & capital

Establish the project LLC, ownership, and capital stack.

What to confirm

Document the QOF and project-company roles, cash equity, ordinary equity, any contributed property, loans, sponsor interests, decision rights, fees, and waterfall.

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07
Written plan

Prepare the budget and spending schedule.

What to confirm

Document funding receipts, designated uses, milestones, responsible parties, and actual spending. If relying on the working-capital safe harbor, test its conditions; a 31-month plan is not an unconditional extension.

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08
Annual work

Assign compliance, accounting, and reporting owners.

What to confirm

Establish the testing calendar, records, annual returns, investor reporting, and specialist engagements. Include ongoing business activity and property requirements.

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09
Operations & exit

Align financing and exit with investor timelines.

What to confirm

Model the holding strategy, year-five tax liquidity, potential refinancing distributions, and sale mechanics. Each investor has a separate clock; a ten-year benefit threshold is not a guaranteed exit date.

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Scope: prospective 2027-and-later investments. Review original-program transactions and transition cases separately. Updated September 29, 2026.

Sources: IRS transition guidance · Fund and business rules · Investor rules

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