IRS Form 8610 (Schedule A) – IRS Forms, Instructions, Pubs 2026 – The Low-Income Housing Tax Credit (LIHTC) program is a vital federal incentive aimed at promoting the development of affordable rental housing across the United States. For state housing credit agencies managing these credits, IRS Form 8610 Schedule A serves as an essential tool for reporting carryover allocations. This form ensures compliance with Internal Revenue Code requirements while facilitating the carryover of unused credits to future years. In this comprehensive guide, we’ll explore the purpose of Schedule A, who needs to file it, filing deadlines, line-by-line instructions, and key considerations for 2025 and beyond. Whether you’re a tax professional, housing agency administrator, or developer involved in LIHTC projects, this article provides actionable insights to navigate the process effectively.
What Is IRS Form 8610 Schedule A?
IRS Form 8610 Schedule A, officially titled “Carryover Allocation of Low-Income Housing Credit,” is a one-page attachment to Form 8610. It is used exclusively by state housing credit agencies to document and report carryover allocations of LIHTC. Carryover allocations allow agencies to assign credits to qualified low-income housing projects before the buildings are fully placed in service, bridging the gap between initial allocation and actual credit utilization. This mechanism is crucial for projects that span multiple years, ensuring that credits from one year’s ceiling can be carried forward without loss.
The form captures details such as the allocation amount, type (building-based or project-based), and any applicable credit percentages. Only one Schedule A is required per project receiving a carryover allocation in a given calendar year. For projects impacted by major disasters, additional copies may be attached to indicate relief under Revenue Procedure 2014-49, without affecting the main Form 8610 calculations.
Purpose of the Carryover Allocation in LIHTC
The primary goal of Schedule A is to report carryover allocations under Section 42(h) of the Internal Revenue Code. This allows state agencies to allocate a portion of their annual credit ceiling to projects in advance, supporting the timely financing and construction of affordable housing units. Without carryover provisions, unused credits could expire, hindering development efforts.
Key benefits include:
- Flexibility for Multi-Year Projects: Credits can be carried over if a building isn’t placed in service by year-end.
- Compliance with Credit Ceilings: Helps agencies reconcile their total allocations against the state’s annual limit.
- Disaster Relief Integration: Agencies can note extensions or modifications due to federally declared disasters.
Amended allocations are also handled through this form, marked accordingly in the header.
Who Must File IRS Form 8610 Schedule A?
Filing responsibility lies solely with state housing credit agencies, not individual building owners or developers. These agencies, such as those under state housing finance authorities, use Schedule A to report all carryover allocations made during the calendar year. Building owners provide necessary information to the agency but do not submit the form themselves.
If an agency grants relief for carryover allocations under Rev. Proc. 2014-49 due to major disasters, they must attach copies of the relevant Schedules A to their Form 8610. This applies only to approvals made since the last filing.
When and Where to File Schedule A
Schedule A must be attached to Form 8610 and filed in the calendar year of the carryover allocation. The filing deadline aligns with Form 8610, typically due by the end of February following the allocation year, though agencies should confirm with IRS guidelines.
Submit the form to the IRS Philadelphia Campus or as specified in the latest instructions. For the most current version (revised December 2024 for 2025 use), download from the official IRS website. Electronic filing may be available; check IRS updates for 2026 requirements.
Step-by-Step Instructions for Completing Schedule A
Filling out Schedule A requires precise details to avoid compliance issues. Below is a line-by-line breakdown based on the form’s specific instructions.
Header Information
- Enter the housing credit agency’s name, EIN, and address.
- Check the box if granting carryover allocation relief under Rev. Proc. 2014-49.
- Check if this is an amended carryover allocation.
Line 1a and 1b
- Provide the name and address of the building owner receiving the allocation.
Line 2
- Enter the owner’s taxpayer identification number (with dashes).
Line 3a
- Indicate if the allocation is building-based (Section 42(h)(1)(E)) or project-based (Section 42(h)(1)(F)).
Line 3b
- Check “Yes” if subject to the nonprofit set-aside under Section 42(h)(5); otherwise, “No.”
Line 3c
- Reserved for future use (leave blank).
Line 4
- Enter the carryover allocation date (when signed by the agency’s authorized official). This must match the Form 8610 year.
Line 5
- Input the carryover allocation amount. Use building-specific for building-based or total project for project-based.
Lines 6a–6c
- Complete only if there’s a binding agreement and an election for applicable percentages other than the placement-in-service month (per Regulations 1.42-6 and 1.42-8).
- 6a: Maximum applicable credit percentage for acquisition costs.
- 6b: For rehabilitation expenses.
- 6c: For new construction expenses.
- Note minimum percentages: 9% for non-federally subsidized buildings post-July 30, 2008, and 4% for certain federally subsidized buildings post-December 31, 2020.
Sign and date the form as the authorized agency official.
Recent Updates and Considerations for 2025–2026
The December 2024 revision of Schedule A incorporates updates from recent legislation, including the Taxpayer Certainty and Disaster Tax Relief Act of 2020. Key changes include clarified minimum applicable percentages and enhanced disaster relief provisions. Agencies should review IRS Revenue Rulings like 2021-20 and Procedures like 2021-43 for compliance.
For projects in states like Minnesota or Arkansas, state-specific qualified allocation plans (QAPs) may impose additional requirements, such as 10% basis expenditure tests for carryover validity.
Common FAQs About IRS Form 8610 Schedule A
- What happens if a carryover allocation is amended?
- File an amended Schedule A, checking the appropriate box, and attach it to an amended Form 8610 if necessary.
- Can individual taxpayers file this form?
- No—only state housing credit agencies handle filing.
- How does disaster relief affect filing?
- Attach copies with the relief box checked for affected projects, but these don’t impact Form 8610 totals.
- Where can I find the latest form?
- Download from IRS.gov, ensuring you use the December 2024 revision for 2025 allocations.
Conclusion: Ensuring LIHTC Compliance with Schedule A
Mastering IRS Form 8610 Schedule A is key to maximizing the benefits of the Low-Income Housing Tax Credit program. By accurately reporting carryover allocations, state agencies support the creation of much-needed affordable housing while maintaining IRS compliance. Always consult the official IRS resources and consider professional tax advice for complex scenarios. For the downloadable PDF, visit the IRS website directly. Stay updated on any 2026 changes to keep your projects on track.