PAT Tax – Initial Determination Letter on the Way
July 24, 2026Based on a recent X posting by Mayor Mamdani and a new webpage on New York City’s website, it appears that “initial determinations” assessing New York City’s newly-enacted pied-a-terre tax (PAT Tax) were transmitted on July 23, 2026. So, owners potentially subject to the PAT Tax should monitor carefully their regular and electronic mail.
Because the strict 30-day appeal period starts upon transmission (not receipt) of an initial determination, the 30-day appeal period for initial determinations sent on July 23, 2026, began running on July 24, 2026, and will end on Saturday, August 22, 2026.
As some documentation necessary for an appeal may prove difficult to obtain, an owner potentially subject to the PAT Tax should start work as soon as possible on any available appeal. In particular, an owner seeking to rely on the PAT Tax lease exemption (i.e., occupancy by lessee under a one-year lease) may face significant hurdles in gathering the necessary proof of residency from the lessee (who may be an unrelated third party with no inclination or obligation to cooperate with the owner on any PAT Tax appeal). The New York City Department of Finance (DOF) has declared that the inability to gather documentation from a lessee or other third party does not excuse payment of or extend the appeal period for the PAT Tax.
The above webpage link connects to DOF’s resources on the PAT Tax, including FAQs and appeals (done electronically). At this time, we do not know whether DOF is finished with initial determinations for the current property tax year (2026/27) or is preparing to send additional batches. Therefore, owners should remain vigilant and continue to monitor carefully their regular and electronic mail for future mailings and the property tax rolls (required to amended for PAT Tax purposes by July 25, 2026).
Once again, the 30-day appeals period for the initial determinations sent on July 23, 2026, began running on July 24, 2026, and will end on Saturday, August 22, 2026.
If you need more information about the PAT Tax or have questions about how the PAT Tax applies to your situation, please contact the PAT Team.
Mark A. Limardo at +1 212 592-1494 or [email protected]
Andrew B. Freedland at +1 212 592 1623 or [email protected]
© 2026 Herrick, Feinstein LLP. HERRICK® is a registered trademark of Herrick, Feinstein LLP. This alert is provided by Herrick, Feinstein LLP to keep its clients and other interested parties informed of current legal developments that may affect or otherwise be of interest to them. The information is not intended as legal advice or legal opinion and should not be construed as such.