Beginning work without NPS approval

This former medical clinic in Madison, Wisconsin, was rehabilitated for a new use as residential apartments.
Photo: NPS files

If the rehabilitation work begins before the application is submitted, can the project be approved while it is underway or when it is finished?

Answer
This is never recommended. The program regulations state that owners who begin rehabilitation work prior to getting approval from the National Park Service do so at their own risk. If a project has already begun before it is reviewed by the National Park Service, and if some of the work does not meet the Standards, the owner may be required to do remedial work in order for the project to meet the Standards and to receive the tax credit. Or the project could be denied approval outright, in which case the owner would not be eligible for the credit.

Also, by federal regulation, a rehabilitation project completed prior to submitting a request for “certified historic structure” status cannot qualify for the rehabilitation tax credit. Therefore, it is very important that owners apply for the rehabilitation tax credit before completing work, and preferably, well in advance of beginning work.

For More Information

Tax Aspects of Historic Preservation - Frequently Asked Questions