The IRS has issued adjusted instructions for form IRS-8609 HERE. Amended instruction for Line 10 (c) and (d) include provisions relating to the option to elect the Income Average Test, referred to on the 8609 as "Income Average."
As we discussed in our ongoing Costello Blog series, Aspire to Average, the 2018 Omnibus Tax Act added a new minimum set-aside (MSA) to the options available. As the MSA is an irrevocable election, the new option is only available to properties that have not elected the MSA by submitting the form 8609 after the first year of the credit period. As the law change happened before tax returns were due in 2018, many owners held off making the election until the IRS made changes to the form to allow for the election.
We have updated the published Blog series to reference the new form. The first in the series is HERE.