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The IRS issued a safe-harbor procedure that taxpayers may follow for determining the deduction for depreciating passenger vehicles when they are eligible for 100% bonus depreciation but are also subject to the Sec. 280F limits on deductions for luxury automobiles.


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The election out of bonus depreciation for a partner's Sec. 743(b) adjustments is made independently from the election out of bonus depreciation for the partnership's tax basis in the property. The proposed regulations have provided guidance and answers for many questions that taxpayers and providers were asking after the enactment of the TCJA.
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Bonus depreciation in Sec.
Legislation through the years has modified the bonus depreciation bonus issues in 2019 now 100% and property that is considered to be "qualified.
One of those changes was eliminating the "original use" requirement, so that taxpayers can now claim bonus depreciation on used property that they acquire Sec.
The proposed regulations provide new rules and definitions for applying bonus depreciation to such acquisitions of used property.
Such netbet codes 2019 bonus issues in 2019 not have been used previously by the taxpayer or its predecessor and cannot be acquired from a related party or in certain tax-free transactions.
There is a special rule for members of a consolidated group.
Most importantly, the proposed regulations define previous use as having a "depreciable interest in the property at any time prior to such acquisition.
As written, the definition is very broad, and the proposed regulations provide some helpful examples for applying this test.
For example, if a taxpayer source acquires a depreciable interest in 50% of an asset and subsequently acquires an additional depreciable interest in the same property, the proposed regulations provide that the additional depreciable interest is not bonus issues in 2019 as being previously used by the taxpayer.
However, if the taxpayer had sold its original bonus issues in 2019 interest in the asset and subsequently acquired a different 50% interest in the asset, that new portion up to the amount for which it had previously held an interest is treated as being previously used by the taxpayer.
Another example provides click to see more if a lessee acquires the property it is leasing, the additional basis acquired in the property over the lessee's own improvements to the property may be eligible for bonus depreciation.
The proposed regulations also have special rules for when to test whether property is acquired article source a related party, including special rules for consolidated groups.
Several examples are very helpful.
While the proposed regulations clarify the used property acquisition requirements, they create several new burdens and questions for taxpayers to consider.
The rule appears to require tracking of every asset ever owned by the taxpayer or its predecessor from prior to the TCJA until such time as bonus depreciation is phased out or the used property rules are changed.
This tracking will be burdensome to large and small taxpayers alike.
Keep in mind that used property is not a separate category for the election out.
A taxpayer would have to elect out for both new and used property in each category for which the taxpayer purchased used property.
And how would it be applied to assets that could have been owned by the taxpayer in the past?
Does some or all of that property qualify for bonus depreciation?
For a detailed discussion of the issues in this area, see "Tax Clinic: Proposed Bonus Depreciation Regs.
Provide Answers, Create New Questions" in the of The Tax Adviser.
Tax Section membership includes a one-year subscription to the The Tax Adviser.
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Prospective purchasers of aircraft seem universally interested in 100 percent bonus depreciation, but, as a taxpayer, the purchaser should not assume either that the aircraft will be eligible for.


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Total 5 comments.