Portfolio Screening

The 179D Project Audit Every Architecture and Engineering Firm Should Perform

Your project list is a better starting point than a blanket assumption about missed deductions—provided the review separates promising evidence from wishful estimates.

Last reviewed: September 17, 2026

Section 179D | Architecture & Engineering | Internal Portfolio Review

Here, “audit” means an internal portfolio screen—not an IRS examination. The objective is to turn scattered project history into an organized inventory that shows what is known, what is missing, and which gaps are realistically solvable.

A useful screen does not begin by multiplying every building’s area by a maximum rate. It begins with owner identity, project dates, actual design scope, installed systems, and supporting records. Those facts determine whether deeper technical and tax work is warranted.

Inventory

Capture the project before estimating the opportunity

For each project, record a stable project ID, legal owner, location, gross area, building type, designed systems, responsible discipline, and the documents that show technical authorship. Keep owner status separate from occupant name and project marketing language.

Do not upload sensitive client records to a public screening page. Use the inventory as a private index to controlled files, with an assigned reviewer and a next action for each project.

Illustrative portfolio-screening funnel

The counts show workflow attrition, not expected conversion rates.

Projects inventoried20

Initial internal list

Tax-exempt-owner candidates8

Ownership still requires verification

Clear design evidence5

Technical authorship appears supportable

Ready for deeper review3

Date and technical records are available

Hypothetical counts supplied in the editorial brief; not NABiTax performance data.
Illustrative portfolio-screening funnel: accessible data
ItemValueNote
Projects inventoried20Initial internal list
Tax-exempt-owner candidates8Ownership still requires verification
Clear design evidence5Technical authorship appears supportable
Ready for deeper review3Date and technical records are available

Four clocks

Construction start, service, deduction year, and filing date are different

Construction-start evidence addresses the current-law cutoff. Placed-in-service evidence helps identify when qualifying property became ready and available. The deduction year depends on the governing route and facts. The filing date addresses when the return or other permissible procedure was used.

Do not label a prior year open from the project date alone. Refund limitations generally depend on actual filing and payment facts, while some partnerships may use administrative adjustment procedures rather than ordinary amended returns. The CPA should own that procedural conclusion.

Evidence fields

Add allocation, certification, labor, and prior-deduction status

A promising owner and design role can still stall without a written allocation, technical model, field inspection, certification, eligible-cost support, or required labor records. Track each category explicitly rather than collapsing them into a single confidence score.

The construction cutoff excludes property whose construction begins after June 30, 2026 under current law. Preserve property-level evidence; a contract date by itself should not be described as conclusive proof.

Evidence-completeness matrix

Missing categories guide follow-up; they do not calculate eligibility.

Review pointEvidence or measureWhy it matters
Project AReadyOwner, dates, design records, and technical file present.
Project BMissing evidenceRequest allocation contact and placed-in-service record.
Project CNot currently supportableOwner identity and technical authorship remain unresolved.
Illustrative queue labels only.

Three queues

Prioritize solvable gaps—not the largest hypothetical number

Use three queues: evidence ready for technical review, evidence missing but potentially obtainable, and not currently supportable. A smaller project with a clear owner, strong specifications, reliable dates, and accessible contacts may deserve attention before a larger project built on assumptions.

Review the queues on a recurring schedule. Assign one responsible person, document the next request, and set a milestone. If the evidence changes, move the project without treating the movement as an eligibility determination.

One sample project changes queues

A document request can improve readiness without guaranteeing qualification.

Missing

No service record

Request

Obtain commissioning file

Received

Validate date and scope

Technical review

Proceed conditionally

Workflow movement is not an eligibility score.

Prepare the review

Give the reviewer one row that answers the next question

  • Project ID, address, area, and legal owner
  • Designed systems and named technical author
  • Construction-start evidence
  • Placed-in-service evidence
  • Potential deduction and filing years kept separate
  • Allocation and owner-contact status
  • Model, inspection, and certification status
  • PWA records or applicable exception review
  • Prior building deductions and eligible-cost records
  • Assigned reviewer and next milestone

Common questions

Practical answers before the review

How far back should we inventory projects?

Inventory can begin broadly, but a tax adviser must assess the governing historical rules and filing procedures before any year is treated as available.

Which fields should we collect first?

Start with project ID, legal owner, address, area, systems, design author, construction start, service date, and available evidence.

Does a screening score establish eligibility?

No. Screening only prioritizes work; it does not replace technical certification, allocation, or tax analysis.

Project review

Bring the project record into one coordinated review.

NABiTax can help organize ownership, design responsibility, allocation, technical analysis, and filing support without assuming an outcome.