Michigan Historic Preservation Tax Credit: Compliance Requirements

Awardee must submit Part 3 (Certification of Completed Rehabilitation) application with supporting photographs showing that actual completed work matches the approved Part 2 project plan and meets the Standards.

Deadline: After project completion, before claiming credit; SHPO reviews and approves within 120 days of receipt

Source: SHPO Application Instructions, Part 3 requirements; R 206.208

Awardee must report credit on appropriate Michigan tax return (Form 5803 for post-2020 approvals, Form 3581 for earlier approvals) and attach SHPO Certificate of Completed Rehabilitation; credit amount must equal SHPO-certified amount.

Deadline: With annual tax return filed for year credit is claimed; form must include project number assigned by SHPO

Source: Michigan Tax Forms 5803 and 3581 instructions; Michigan Dept of Treasury

Awardee must ensure completed rehabilitation work conforms fully to the Secretary of the Interior's Standards for Rehabilitation as verified by SHPO inspection; work that deviates from Standards risks Part 3 certification denial and loss of tax credit.

Deadline: Must submit Part 3 certification application after project completion with photographs demonstrating conformance

Source: SHPO Application Instructions, Part 3 section; R 206.208

Awardee must pay non-refundable SHPO review fees at each application stage (Part 1, Part 2, Part 3); fee amounts vary by qualified expenditure amount or project category. Payment must be received before SHPO issues any decision.

Deadline: With each application submission (Part 1, 2, and 3); no decisions issued until payment received

Source: SHPO Application Instructions, Parts 1–3 fee schedules; R 206.209

Awardee must begin claiming approved credits within five years of receiving SHPO's Certificate of Completed Rehabilitation; credits not claimed within five years are forfeited.

Deadline: First credit claim must be filed within five years of Part 3 certification issuance

Source: Plante Moran FAQ; Michigan tax credit forms (Form 5803, 3581 instructions)

If awardee transfers/assigns the tax credit to another party, both initial assignment and any subsequent reassignments must be approved in writing by SHPO; unauthorized assignment or reassignment is invalid.

Deadline: Assignment/reassignment certificate must be obtained from SHPO before credit is claimed by assignee; timing is year of certification

Source: Michigan tax credit forms 3581, 5803; Plante Moran HTC FAQ

For non-residential projects, qualified rehabilitation expenditures must equal or exceed 10% of the property's State Equalized Value (SEV); awardee must provide SEV verification from local assessor with application.

Deadline: Must be submitted with Part 2 application; owner-occupied residential projects are exempt from SEV requirement

Source: SHPO Application Instructions, Part 2 & 3; R 206.205

Credits vest pro rata over a five-year compliance period at 20% per year; if property ownership transfers during vesting period, seller and SHPO must execute written agreement ensuring property remains historic and providing state recapture mechanism for nonvested credits.

Deadline: Agreement must be executed before ownership transfer; applies during entire 5-year vesting window

Source: Plante Moran FAQ citing Michigan HTC program rules; PA 343 of 2020

Upon destruction of the certified historic building (e.g., fire, demolition), SHPO may revoke Part 3 certification, triggering immediate recapture of all vested and nonvested credits.

Deadline: Recapture triggered upon loss of property; must be reported on subsequent tax return

Source: Plante Moran FAQ citing Michigan HTC program recapture rules