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COST SEGREGATION
A well documented Cost Segregation Analysis on a building or buildings can help the taxpayer identify and segregate the costs from the longer life 1250 Real Property, to the shorter-lived 1250 Property, and 1245 Personal Property classifications for accurate accelerated depreciation. Cost Segregation Analysis for federal tax depreciation purposes has been available to taxpayers since the demise of the Investment Tax Credit (ITC) at the end of 1986, and the realignment of depreciable tax lives, which took effect on January 1, 1987. In the landmark Federal Tax Court case: Hospital Corp of America v. The Commissioner, in 1997, it was determined that the existing Tax Court Case Law for Investment Tax Credit was the basis for establishing and classifying 1245 Personal Property and 1250 Real Property for Cost Segregation Analysis purposes. K&K professionals are well versed in ITC case law In 1987, the Modified Accelerated Cost Recovery System, MACRS, depreciation was aligned into three major categories: Lookback Cost Segregation AnalysisAs a result of Revenue Procedure 96-31 and several subsequent Rev. Proc.’s, the taxpayer is allowed “lookback” in time, and if a building has not already been analyzed for Cost Segregation, the taxpayer is allowed to prepare a Lookback Cost Segregation Analysis and claim all prior unclaimed depreciation on the building or buildings in the current year of filing. The taxpayer must file a form 3115 Change in Method to accompany the additional depreciation. This Lookback Cost Seg Analysis is also known as a Catch-Up Depreciation Study. Guidelines for qualifying for a Lookback Cost Seg or a Catch Up Depreciation study include; the taxpayer must still own the property; the property has to have been placed in service on or after January 1, 1987. From January 1, 1987 through May 13, 1993 any building placed in service must be depreciated over 31.5 years. After May 13, 1993, any building placed in service must be depreciated over 39 years. Lookback Cost Seg is a subset of Fixed Asset Reclass Analysis. Detailed Information: |
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