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MICHIGAN SPECIAL ACTS

Michigan PA 198 & Special Acts Guide

Michigan's special acts — PA 198 Industrial Facilities Tax, OPRA, Brownfield TIF, and the Commercial Rehabilitation Act — can dramatically reduce the property tax burden on qualifying projects. Here's how each works and how they intersect with the appeal process.

SPECIAL ACTS OVERVIEW

How Michigan Special Acts Reduce Commercial Tax Burden

Michigan uses a family of "special acts" to incentivize industrial investment, redevelopment of obsolete buildings, and environmental cleanup of contaminated sites. Unlike a traditional appeal that challenges an assessor's valuation, special acts grant a negotiated tax benefit through a local unit resolution and State Tax Commission approval. For industrial and commercial owners, stacking the right certificate on top of a fair assessment is often the single biggest lever for reducing annual tax exposure.

The headline program is PA 198 of 1974, the Industrial Facilities Tax Act. A PA 198 certificate replaces the general ad valorem tax on qualifying new industrial investment with an Industrial Facilities Tax (IFT) that effectively delivers a 50% abatement on the millage portion of the tax bill for up to 12 years. Rehabilitation of existing industrial buildings can also qualify. The program is widely used across Michigan's manufacturing corridors in Wayne County, Oakland County, Macomb, Kent, and Genesee counties.

Michigan also runs parallel programs for non-industrial properties: the Obsolete Properties Rehabilitation Act (OPRA), Brownfield Tax Increment Financing, and the Commercial Rehabilitation Act. Each has its own eligibility rules, abatement formula, and filing path through the local unit and the State Tax Commission.

  • PA 198 IFT: 50% abatement on new industrial investment for up to 12 years
  • OPRA: freezes taxable value on obsolete commercial or mixed-use buildings during rehab
  • Brownfield TIF: captures incremental taxes to reimburse environmental cleanup costs
  • Commercial Rehabilitation Act (PA 210): freezes taxable value for qualified commercial rehab projects

Special acts reduce the rate or base — but they do not guarantee the assessor got your value right. Start with your Michigan property tax strategy, compare it against the uncapping rules, and make sure any industrial property tax appeal is coordinated with your certificates before you request a free review.

Michigan industrial facility owners reviewing PA 198 IFT certificate application

THE FOUR CORE PROGRAMS

Michigan's Special Acts at a Glance

Each program targets a different property type and policy goal. Knowing which certificate fits your project determines your filing path, your abatement formula, and how your assessment should be analyzed each year.

PA 198 Industrial Facilities Tax

Replaces ad valorem tax on new or rehabilitated industrial real and personal property with the IFT. Effective 50% abatement on the millage share for up to 12 years, granted by local unit and confirmed by the State Tax Commission.

OPRA Obsolete Properties Rehab

Freezes taxable value of qualifying blighted or obsolete commercial and mixed-use buildings during rehabilitation. Applies inside local-unit-designated Obsolete Property Rehabilitation Districts for up to 12 years.

Brownfield Tax Increment Financing

Captures the incremental property tax generated by a redevelopment and reimburses eligible environmental cleanup and site prep costs. Administered through a local Brownfield Redevelopment Authority work plan.

Commercial Rehabilitation Act (PA 210)

Freezes taxable value on qualified commercial property rehabilitation inside a designated Commercial Rehabilitation District. Up to 10 years of relief on the rehab portion of the investment.

HOW TO APPLY

The Special Acts Application Path

Every Michigan special act runs through the same three-stage path: eligibility, local approval, and ongoing compliance. Miss a step and the certificate can be denied, delayed, or revoked.

01

Identify Eligibility

Confirm your project type and location qualify. PA 198 requires manufacturing or qualifying high-tech operations; OPRA requires an obsolete commercial or mixed-use building; Brownfield requires a facility, functionally obsolete, or blighted designation; PA 210 requires a qualified commercial rehab.

02

Apply Through the Local Unit

File the appropriate State Tax Commission form with your city, village, or township. The local unit must first establish the district, then adopt a resolution approving your certificate. The application is forwarded to the State Tax Commission for final approval.

03

Monitor Annual Compliance

Once granted, you must report actual investment, keep the project on schedule, and cooperate with annual review. Certificates can be revoked for material non-compliance, so coordinate your assessment reviews and appeals with your certificate each year.

APPEALS + CERTIFICATES

When Appeals and Special Acts Intersect

A PA 198 or OPRA certificate does not freeze the underlying assessment — it only changes how the tax is calculated on the portion it covers. Each year, the assessor still sets a State Equalized Value on both the exempt and non-exempt components, and an inflated SEV can quietly erode the benefit you expected. Disputes over that underlying value are resolved through the Michigan Tax Tribunal, and the calculation still sits on top of the Proposal A taxable value cap framework. For a step-by-step walkthrough, see our property tax appeal process guide.

01The IFT millage is applied to an assessor-determined value — if that value is too high, a 50% abatement on an inflated base still overcharges you.
02Land is almost always excluded from PA 198 abatement, so the land SEV remains fully appealable on the general tax roll.
03OPRA and PA 210 freeze only the rehabilitation portion — new additions, land, and non-qualifying improvements continue to be reassessed annually.
04Brownfield TIF captures the incremental tax, which means a correct assessment directly affects how quickly eligible cleanup costs are reimbursed.
05When a certificate expires, the property reverts to the full ad valorem roll — plan the appeal strategy before that transition year, not after.
06March Board of Review and Michigan Tax Tribunal deadlines still apply to special-acts properties; missing them waives your appeal rights for the year.

A PA 198 Industrial Facilities Exemption Certificate removes qualifying new or rehabilitated industrial property from the general ad valorem tax roll and places it on the Industrial Facilities Tax roll. The IFT is calculated using roughly half of the local millage rate, producing an effective 50% abatement on the millage portion of the bill for up to 12 years. Certificates are granted by the local unit and confirmed by the State Tax Commission. For deeper context on Michigan's overall industrial tax environment, see our industrial property tax appeals page.

A PA 198 certificate can be granted for any term up to 12 years, as determined by the local unit's resolution. Many local units approve the full 12 years for significant new construction and a shorter term for rehabilitation projects. When the certificate expires, the property is automatically placed back on the general ad valorem roll at its current assessed value — which is why it's critical to coordinate any Michigan assessment strategy around the expiration year.

Yes. A certificate does not waive your right to appeal the underlying taxable value or State Equalized Value. The IFT millage is applied to an assessor-determined base, so if that base is inflated, the abatement is being calculated off the wrong number. Land is almost always excluded from PA 198 and continues to be fully taxable on the general roll, which is why coordinating the certificate with an appeal — and with Michigan's uncapping rules after any ownership change — matters so much.

The Obsolete Properties Rehabilitation Act (PA 146 of 2000) targets blighted, functionally obsolete, or contaminated commercial and mixed-use buildings. Instead of cutting the millage in half like PA 198, OPRA freezes the taxable value at its pre-rehab level for up to 12 years, so the owner doesn't pay tax on the value added by the rehabilitation. PA 198 is industrial-only; OPRA is designed for commercial, multifamily, and mixed-use downtown redevelopment. Both require a local district and State Tax Commission approval.

Brownfield Tax Increment Financing captures the incremental property tax revenue generated after a contaminated, functionally obsolete, or blighted site is redeveloped. Those incremental dollars are redirected to reimburse eligible environmental cleanup, due care, and site preparation costs through an approved work plan. It's not a rate cut — it's a redirection of future tax dollars back to the project. A correctly set assessment still matters, because it determines how much increment is captured each year. You can request a free review to audit that calculation.

All Michigan special acts use a two-step approval process. The local unit (city, village, or township) first establishes the required district and then adopts a resolution approving the certificate after a public hearing. The application is then forwarded to the Michigan State Tax Commission, which has final approval authority. Because every local unit sets its own policies on term length and eligibility, the process can vary significantly across counties — see our Michigan overview for county-level context.

APPEAL DEADLINE

Don't Let the Deadline Decide for You

Once the filing window closes, you're locked in for another year — even if your taxes are wrong.

Submit your details now, and we'll tell you where you stand.

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SPECIAL ACTS CERTIFICATE ON YOUR PROPERTY?

Make Sure Your PA 198, OPRA or Brownfield Benefit Isn't Being Eroded

A certificate is only as valuable as the assessment it sits on top of. We review the underlying SEV, land value, and non-exempt components for Michigan industrial and commercial owners — no fee unless we save you money.

Michigan capitol building representing PA 198 and special acts oversight