Relating to the deadline for filing an application for certain ad valorem tax exemptions or allocations and the calculation of the penalty for filing a late application for such an exemption or allocation.

Contracts

• Third-Party Tax Consultants: Renegotiate Master Service Agreements (MSAs) immediately. If fee structures are based on "penalty avoidance" or a percentage of "tax savings," the value of these services has decreased due to the statutory penalty cap.
• Triple Net (NNN) Leases: Landlords must review lease terms to ensure the new, lower administrative penalties can still be passed through to tenants if the penalty results from tenant delays in reporting inventory data.

Hiring/Training

• Cross-Departmental Synchronization: Finance teams (handling Renditions) and Tax/Legal teams (handling Exemptions) must be integrated. Staff must be trained that obtaining a Rendition extension now creates a mandatory legal extension for Exemption filings.
• "Good Cause" Documentation: Compliance officers must be trained to document operational failures (e.g., IT outages, records destruction) immediately to support potential "good cause" extension requests.

Reporting & Record-Keeping

• Affirmative Defense File: You must retain the written Rendition Extension Approval (Section 22.23(b)) physically and digitally. This document must be attached to any Exemption application filed between May 1 and May 15 to force CAD acceptance.
• Forms: Utilize Form 50-113 (Freeport) and Form 50-144 (Allocation). No new forms are mandated, but cover letters must now reference the Rendition extension.

Fees & Costs

• Penalty Reduction: The law eliminates the risk of penalties exceeding the tax bill itself. Penalties are now capped at the lesser of 10% of the tax savings or 10% of the tax imposed.
• Budgeting: Adjust reserve funds for tax disputes downward for the 2026 cycle due to the lowered liability cap.