# REIT year-end preparation — December 31, 2026 Evidence cut-off: 2026-12-31 · Forward-looking preparation edition · prepared October 9, 2026 · not a completed close Prepared / updated: 2026-10-09 SeniorCRE® is operator-controlled operating infrastructure for senior housing & care. The Operator-Controlled Operating Record is designed and not yet implemented in any community. IRC §856 qualification support is under evaluation for the roadmap — not confirmed, not built. No production result, live third-party connector, independently validated isolation control or tax-counsel approval is claimed. Named product-owner review: pending. Named tax-counsel review: pending. No expert approval is claimed. ## Plan the December 31 evidence cut-off - [ ] For a calendar-year taxpayer, name the entity valuation owner, source-delivery cadence and quarter-end asset evidence. For a different tax year, counsel determines the applicable periods; December 31 is not automatically its tax-year end. ## Reconcile full-year classifications - [ ] Prepare the 95% and 75% annual gross-income tests, lease and TRS classifications, adjustments and supporting counsel decisions. Do not substitute a Q3 year-to-date ratio for full-year analysis. ## Revisit distribution and return assumptions - [ ] Reconcile taxable-income estimates and distributions with Finance and tax counsel. The 90% distribution requirement generally uses REIT taxable income computed without the dividends-paid deduction and excluding net capital gain; other distribution and excise-tax considerations are separate. ## Check exchanges against the return deadline - [ ] Record 45-day identification and completion by the earlier of 180 days after transfer or the tax-return due date including extensions. Ask counsel and the qualified intermediary about applicable relief; do not assume every exchange has a full 180 days. ## Reproduce and authorize the year-end package - [ ] Test locked reports, definition versions, late-arrival handling, consent, access and export rights. Capture named product-owner, Finance and tax-counsel dispositions before reliance; no December 31 results or sign-off are available today. ## Sixteen evaluation criteria — preserve evidence, do not assume features - [ ] [1. IRC §856 75% asset test: quarter-end evidence and between-close warnings](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#asset-test) — A recomputation for one entity and one prior period you select, with the source rows behind both sides of the ratio. - [ ] [2. 95% and 75% gross income tests with RIDEA/SHOP treatment](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#income-tests) — The classification rule set, the line-level mapping for one RIDEA entity, and the change history on both. - [ ] [3. §856(c)(4)(B)(ii) 25% TRS securities asset limit for applicable 2026 tax years](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#trs-cap) — An alert configuration showing threshold, recipient role, and the log of a fired alert. - [ ] [4. 90% distribution requirement rollforward for the current tax year](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#distribution) — A rollforward view with the estimate basis, the version history, and the approver. - [ ] [5. §856(d) rents-from-real-property classification at clause level](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#rents) — A clause-level classification for one service-bundled lease, and the reviewer who approved it. - [ ] [6. Coverage and covenant evidence computed per property](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#covenants) — A one-hop trace from one covenant figure to the operator rows that produced it, with the definition version attached. - [ ] [7. NOI variance with lineage to the operating event](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#noi-variance) — One variance walk from portfolio NOI to a named operating driver at a named community. - [ ] [8. Occupancy quality, not just occupancy percentage](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#occupancy-quality) — The metric definitions, who owns each definition, and the last time each was changed. - [ ] [9. Entity and operator isolation enforced below the application layer](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#isolation) — The written control description, the test that proves it, and the contract clause on derived-data ownership. - [ ] [10. Named definition authority for every published metric](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#definition-authority) — The definition register with owner, version, effective date, and the approval record for one recent change. - [ ] [11. Reconciliation performed once, under governed rules](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#reconciliation) — One contested figure, the reconciliation rule applied, the approver, and the downstream reports that inherited it. - [ ] [12. Per-source freshness and stale-feed behavior stated in writing](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#freshness) — A latency table by source, plus a screenshot of the view while a feed is deliberately stale. - [ ] [13. Documented integration paths, scored honestly](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#integration-paths) — A source-by-source matrix with method, direction, owner, latency, and a named reference environment for each claim. - [ ] [14. Append-only history, period locking, and reproducible prior reports](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#audit-log) — A reproduction of one prior period report, its approval identities, its override history, and the retention and export terms in the contract. - [ ] [15. §1031 identification and earlier-of completion deadline monitoring](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#exchange-timers) — One disposition with both timers, the alert schedule, and the evidence attached to the entity record. - [ ] [16. Production references and honest maturity disclosure](https://seniorcre.com/reit-compliance-monitoring/evaluation-criteria#production-references) — A dated capability register naming what is built, what is demonstrated, what is roadmap, and what is production-proven. ## Tax rules and review boundaries TRS securities asset limit: 25% for taxable years beginning after December 31, 2025 (Public Law 119-21 §70439 amends §856(c)(4)(B)(ii)); the earlier 20% rule is not the applicable calendar-year 2026 threshold. TRS status under §856(l) is not a gross-income cap. Asset tests are measured at statutory quarter-end; income and distribution requirements are tax-year tests. Entity structure, elections, relief and cure provisions require counsel. Sources: https://www.govinfo.gov/content/pkg/PLAW-119publ21/html/PLAW-119publ21.htm ; https://www.law.cornell.edu/uscode/text/26/856 ; https://www.law.cornell.edu/uscode/text/26/857 ; https://www.law.cornell.edu/uscode/text/26/1031 Not tax, legal or investment advice. This is an evidence-review checklist, not a tax opinion, attestation or deployed SeniorCRE capability.