Notice 2026-11: What to Send Your Tax Preparer

Prepare acquisition dates, component records, and election history for a tax-preparer review of IRS Notice 2026-11.

Updated September 27, 2026 · Stratum Cost Segregation

What the notice addresses

Notice 2026-11 provides interim guidance following changes to section 168(k). It addresses eligibility and elections for additional first-year depreciation. It is not an IRS approval of a cost segregation provider, and it does not establish that every component in a rental building qualifies.

Turn the notice into a document request

Ask the preparer which acquisition and construction records are needed for your facts. Assemble the signed agreement and amendments, purchase closing, construction timeline, and itemized additions. Keep documents tied to the property or component they describe. Avoid a folder of unlabelled invoices that forces the reviewer to infer which project each charge belongs to.

Reconcile the report before applying a rate

Have the provider show how the analyzed cost pool connects to the owner’s records. Identify land, acquired furnishings, later improvements, and costs outside the study’s scope. Confirm that the report explains important assumptions and unresolved items. A rate applied to an unreconciled total can produce a precise-looking calculation without a supported starting point.

Record the filing decisions

The preparer should evaluate applicable elections, required statements, and filing deadlines using the notice and current guidance. Retain a copy of what was actually filed, not only an email discussing an option. If the report arrives after a return has been prepared, coordinate the change instead of assuming the report automatically updates the filing.

Keep the company decision separate

When comparing providers, ask who handles property analysis and who handles tax-return decisions. Confirm whether election questions, prior-year implementation, and state adjustments are included in the engagement or belong to your CPA. A provider’s projected deduction is not a substitute for the preparer’s evaluation of the owner’s usable benefit.

Primary references

Educational information. The return preparer should verify current guidance and apply it to the taxpayer’s facts.

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