Both the Department of Finance’s Real Property Income & Expense (RPIE) statement and the Tax Commission’s Form TC201 collect the same building-level income and expense (I&E) numbers, and—because many owners already reported 2024 operations on TC201-2025—the “total income” and “total expenses” you put on each form should tie out this year. But the two filings serve different purposes, follow different calendars, and ask for different supporting details such as rent rolls, vacancy breakouts, and property-tax expense. Understanding where they overlap—and where they don’t—lets you reuse work while avoiding penalties or a loss of hearing rights.
Who must file and when
| RPIE-2024 | TC201-2025 | |
| Trigger | Mandatory for most properties with an actual assessed value above $40 k in tax classes 2-4 | Required only if you file an application (Forms TC101/109) and want a Tax Commission hearing for most income-producing property types |
| Filing window (this cycle) | Feb 25 – Jun 2 2025 | Attach to the application by Mar 3 2025; if missing and the AV > $750 k, file as a supplemental (TC150) between Mar 3 and Mar 24 2025 |
| Penalties | Up to 5 % of actual assessed value for non-filing and loss of Tax Commission review rights the following year | Application is incomplete without TC201; your hearing will be denied |
Core I&E similarity
Both forms use the same income categories (regulated residential, office, retail, parking, etc.) and basic operating-expense buckets (utilities, insurance, repairs). That is why a clean TC201 export usually drops straight into the RPIE template without re-keying numbers.
The one extra RPIE expense line
- Amortized leasing & tenant-improvement costs appears as one line on the TC201, Section 7, Line k. The RPIE breaks this into two separate lines – Section L(i), Lines 11-12. Report Amortized Leasing Costs and Amortized TI Costs separately on the RPIE.
- For best practices, when you prepare your TC201 earlier in the year, account for the two expenses separately – add them together for the TC201 – but report them separately on the RPIE. (The totals should be the same.)
Recategorizing “Miscellaneous” expenses
- The TC201, Section 9, allows filers to itemize Miscellaneous Expenses. The RPIE specifically tells filers to reclassify miscellaneous expenses and include them in their “proper” category – according to a detailed chart that DOF publishes in the RPIE Worksheet & Instructions file. For example, if Exterminator / Pest Control was a miscellaneous expense on the TC201, it should be rolled up into the Repairs & Maintenance expense line on the RPIE.
- This does not mean that TC201 filers are doing it wrong be itemizing Miscellaneous Expenses. They should continue to itemize. It just means they need to do a little accounting gymnastics to recategorize those expenses on the RPIE.
- If an RPIE filer uses the Line 13 Miscellaneous Expenses, there is a risk that DOF will not include them in its valuation review, which may then increase the assessed value and the property taxes. Get credit for all your expenses by properly categorizing them.
- The subtotal of the pre-tax expenses on the TC201 and RPIE should be the same, even though the individual lines may differ somewhat due to the different categorizations.
Supporting detail that differs
| Requirement | RPIE-2024 | TC201-2025 |
| Rent information | Full electronic rent-roll addendum for properties with assessed value ≥ $750 k, as of Dec 31 2024 (separate Commercial and Residential) | No rent roll; instead, Section 3 asks for a summary of regulated vs. unregulated residential rents as of Jan 5 2025 |
| Vacancy breakout | Vacancy reported by use (residential, office, retail, etc.) | Vacancy captured by floor for non-residential space in Section 4 |
| Miscellaneous expenses | DOF discourages large “Misc.” lines and excludes real-estate taxes, depreciation, mortgage interest, etc. from valuation | Section 9 is a dedicated “Miscellaneous” schedule, allowing amortized common area improvements and lease buy-out costs |
| Property-tax expense | Optional | Reported on Section 7, Line n |
| Confidentiality | Individual RPIE filings are classified and are not disclosable | TC201 is subject to FOIL; rent-roll-type data may be redacted, but most of the schedule is publicly available once filed |
Practical workflow tips
- Start with the TC201. Finishing the Tax Commission filing first gives you income and expense totals you can use on the RPIE.
- Skip the cents. Neither filing wants you to report cents. Round figures to the nearest dollar.
- Map the extras early. Keep a running list of amortized commissions/TI costs and miscellaneous expenses so you can plug them into the RPIE without reopening the books.
- Keep rent evidence handy. While TC201 doesn’t take a rent roll, hearing officers often ask for one, so the spreadsheet you built for RPIE does double duty.
- Mind the calendars. A late RPIE knocks you out of next year’s appeal; a late TC201 knocks you out of this year’s. Put both due dates on your compliance tracker.
- Residential vacancy. Need to report the residential vacancy percentage on the RPIE? Divide the number of vacant apartments by total apartments, as you reported on the TC201 Section 3.
Bottom line
For 2024 operations you will file two government forms that talk to each other: DOF uses the RPIE to estimate tax year 2026/27 valuations, and TC201 lets you challenge tax year 2025/26 valuations at the Tax Commission. Deliver matching totals, reconfigure the extra lines (leasing/TI, detailed miscellaneous), and you’ll satisfy both agencies without redundant work—or unwanted penalties.
This article is for informational purposes only and does not constitute legal advice. Property owners should consult qualified legal professionals regarding their specific circumstances.