File RPIE Statements, Storefront Registration with DOF by June 1
The NYC Department of Finance (DOF) requires certain owners of residential properties to file the Real Property Income & Expense Statement (RPIE) every year. The DOF uses income and expense information gathered each year from this filing to value your property accurately for the 2022–23 tax year. Last year, due to the pandemic, the DOF granted an extension to file RPIE statements and storefront registry filings. This year, however, there’s no extension. The deadline to file the RPIE statement and register storefronts is June 1, 2021.
Rental properties, other than cooperatives, where the occupants pay rent are generally required to file. This includes rental apartment buildings and commercial properties with one or more tenants. If you own an income-producing property with an Actual Assessed Value greater than $40,000 on the 2021–22 tentative assessment roll, you’re required to file an annual RPIE form.
The RPIE 2020 filing deadline is June 1, 2021, and covers the calendar year reporting period from Jan. 1, 2020, to Dec. 31, 2020. However, if the property’s records are maintained on a fiscal year basis, the RPIE will cover the last complete fiscal year as of May 3, 2021. You can refer to the “Actual Assessed Value” shown on Finance’s 2021–22 Tentative Assessment Roll available at https://www1.nyc.gov/site/finance/taxes/property-assessments.page to find your property’s Actual Assessed Value.
You must file electronically unless you apply for and are granted a waiver from electronic filing. You can find electronic filing instructions and the online portal to file the RPIE form at https://www1.nyc.gov/site/finance/taxes/property-rpie.page.
Short form. For RPIE-2020, owners whose property’s “Actual Assessed Value” as shown on Finance’s 2021–22 Tentative Assessment Roll is $250,000 or less can complete a shorter RPIE form as long as the property isn’t a hotel. If the property is eligible, you’ll be given the long or short form option when you begin the filing process online. Either form will fulfill your reporting requirements. Voluntary filers can also elect to use either form.
RPIE or exclusion filing exemption. The following properties aren’t required to file an RPIE or a Claim of Exclusion:
- Properties that have an Actual Assessed Value of $40,000 or less on the 2020–21 Tentative Assessment Roll.
- Residential properties containing 10 or fewer dwelling units.
- Class 1 or Class 2 properties with six or fewer dwelling units and no more than one commercial unit.
- Special franchise properties that are utility properties not municipally owned, located in the public right of way, and are valued by the Office of Real Property Tax Services of the NYS Department of Taxation and Finance.
Preserving tax assessment appeal. If you don’t file an RPIE, the NYC Tax Commission, by law, can deny a hearing for any property that doesn’t file the RPIE-2020 form by the June 1, 2021, deadline. To retain your right to appeal to the Tax Commission, you must file your RPIE on time.
Penalties for late filing or failure to file. The law authorizes monetary penalties for late filing and for failing to file. Income and expense information is needed for tax administration purposes and, therefore, must be received by the deadline. In addition, willful misstatement of facts on an RPIE form is a crime punishable by law.
If you’re required to file the income and expense statement and it’s not received by the June 1, 2021, deadline, the penalty is up to 5 percent of your property’s actual assessed value. If you’re required to file a claim of exclusion and one isn’t received by the June 1, 2021, deadline, there’s a penalty of $100.
The storefront registry requirement with the DOF began last year after the City Council passed a bill mandating the tracking of ground-floor or second-floor commercial premises (storefronts) in an effort to accurately measure vacancies. You must register with the city if you own a property with a qualifying storefront. If there are no storefronts on your property, enter zero for the number of ground-floor or second-floor commercial units on the premises and submit your RPIE to the DOF.
According to the DOF, storefronts typically have windows that face the street and are accessible to the public using a street or interior entrance. They generally display products and signs to make them easily identifiable to the public. Storefront spaces are spaces that are used for retail sales or, without substantial physical alteration to the building or building entrances, could be used for retail sales. Retail sales include the sale of goods, food, or beverages, as well as personal or financial services. Professional offices with only a name plaque on the exterior of the building aren’t considered storefronts.
The storefront registration requirement applies to all tax Class 2 and 4 property owners with ground-floor or second-floor storefronts, even if you’re otherwise exempt from filing an annual income and expense statement. Owners of Class 1 property in commercially zoned areas must register their storefronts if the space was vacant or owner-occupied for any days during the previous year. The size, location, occupancy status, monthly rent, lease status, and owner contact information will be required for each space.
Owners who fail to register or who provide inaccurate data will face fines. They’ll also be required to update the database if the occupancy status or ownership of the building changes within the first six months of the year.
Rent Roll Addendum
Along with the storefront registry requirement, owners of properties that have an actual assessed value of $750,000 or greater must file an addendum containing details about the lease and related information. In the past, submitting a copy of your rent roll sufficed, but the information now required to be submitted is information typically not included on most residential or commercial rent rolls. And it must be submitted electronically in a format and spreadsheet provided by the DOF.
Last year, the DOF extended the deadline to file this addendum. This year, the RPIE and the rent roll addendum don’t have to be submitted at the same time, but both must be submitted by the June 1, 2021, filing deadline.