IRS rules favorably on key bonus depreciation issue

May 2012


In a recently issued private letter ruling (PLR 201214003), the IRS concluded that certain self-constructed property qualifies for the 50-percent additional first-year depreciation deduction (bonus depreciation) under section 168(k)(1) and that some components of the property may qualify for 100-percent bonus depreciation if a proper election is made. Most notable in the PLR is the analysis of when a taxpayer "incurs" costs for purposes of applying the 10-percent safe harbor rule in Reg. sec. 1.168(k)-1(b)(4)(iii)(B)(2) (the 10-percent safe harbor). Observation:The recent PLR follows PLR 201210004, which also addressed, among other things, the analysis of the section 461 standards for purposes of applying the bonus depreciation 10-percent safe harbor.

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