1. Property Acquisitions and Cost Recovery Deductions
Chapter 7
Property Acquisitions and Cost Recovery Deductions

2. Expense vs. Capitalize
Deduction permitted for all “ORDINARY AND NECESSARY” business expenses
Deduction prohibited for “PERMANENT improvements to increase the value of property”
Some types of capitalized costs can be recovered through amortization or depreciation

3. Expense vs. Capitalize
Repairs and maintenance? Source of IRS dispute due to facts.
Capitalize expenditures that increase the value or useful life of an asset.
Environment cleanup and prevention costs: TRA1997 has a provision allowing firms to elect to deduct rather than capitalize expenditures to abate or control hazardous substances at contaminated areas.

4. Tax Basis Tax basis = unrecovered cost (cost - depreciation).
Starting basis generally equals COST basis:
original purchase price regardless of whether acquired by debt, or
FMV of asset if cost more difficult to measure.
Cost recovery of
Inventory = cost of goods sold
Tangible assets = depreciation
Intangible assets = amortization
Natural resources = depletion

5. Cost of Goods Sold
Inventory Methods (must use accrual to account for COGS
1) FIFO
2) specific ID
3) LIFO - If use LIFO for tax, must also use LIFO for books.
In times of inflation, LIFO decreases book and taxable income.

6. Depreciation
Depreciation applies to tangible assets (things you can touch versus intangibles like patents, goodwill) that:
Lose value over time due to wear and tear, obsolescence
Buildings depreciate even though real estate often increases in value.
Have a reasonably ascertainable useful life
Artwork is not generally depreciable.

7. Depreciation MACRS - Modified Accelerated Cost Recovery System
Personalty:
DDB: 3, 5, 7, 10
150% DB:15, 20
General rule is half year convention
Realty: SL method: years residential, 39 years non-residential (specialty realty 20, 25, 50)
Mid Month convention

8. Depreciation Conventions - Personalty
Table 7-2 incorporates a half-year convention - provides only 1/2 of the regular rate in the year the property is put in service.
Anti-Abuse provision Mid-quarter convention
: IF > 40% personalty is acquired during the last quarter of the year, THEN
Compute depreciation separately for EACH quarter’s acquisition using mid-quarter tables in appendix of chapter 7

9. Automobiles
Maximum annual depreciation limit per vehicle, indexed for inflation.
Year 1 $3,160 (1st yr) with bonus $11,060
Year 2 $5,100 (2nd yr)
Year 3 $3,050 (3rd yr)
Year 4 + $1,875 (4th +++ yrs).
Compute depreciation per MACRS, then limit above.

10. Expensing Election – Section 179
Applies to tangible personalty. May expense $500,000 of assets purchased in year of acquisition
Expense cannot create a business loss.
Expense reduced $ for $ by purchases > $2,000,000 in 2014, $200K for 2015+
50% Bonus depreciation on personalty for tax years none after
Planning - if buy a 3-year, 5-year and 7-year asset, which one should you expense?

11. Amortization of Intangibles
Generally requires a determinable useful life.
Organizational costs & Start up costs
Immediately deduct up to $5,000
Amount over $5K amortized over 180 months.
Start-up costs & Organization costs are defined on pg. 177.
Expansion costs may be currently deductible.

12. Leasehold Costs and Improvements
Cost of acquiring lease is amortized over the period of lease.
Improvements to leased property are capitalized and depreciated according to type of property.

13. Purchased Intangibles
Allocate lump-sum price to assets by relative FMVs.
Residual = goodwill.
Tax = 15 years SL
GAAP = 40 years pre No GAAP amortization post evaluate for impairment annually. Book-tax difference is permanent post-2001.