To be depreciable under MACRS, property must be tangible and of a character subject to the allowance for depreciation (often referred to as a “wasting asset”). The property must also be used in a trade or business or held for the production of income. Though there are exceptions, most tangible property of this type is subject to wear and tear and is therefore a wasting asset.
MACRS provides eight categories of property with a recovery period assigned to each category. In addition, MACRS provides three categories that cover most real estate: residential rental property with a 27.5-year recovery period, nonresidential real property with a 31.5-year recovery period, and nonresidential real property with a 39-year recovery period. The categories include property with recovery periods ranging from 3 years to 25 years.
Under §168(c), the “applicable recovery period” is determined by the recovery class of the property. Under §168(e), most personal property is placed in three-year, five-year, seven-year, 10-year, 15-year or 20-year classes. The 15-year and 20-year recovery classes generally include inherently permanent assets, such as land improvements. Most other real estate assets, such as buildings, are placed in the 27.5-year, 31.5-year, or 39-year recovery classes. Railroad grading and tunnel bores are placed in the 50-year category.
Under ACRS, most personal property is placed in the three-year, five-year, or 10-year recovery class, and most realty is placed in the 15-year, 18-year, 19-year, or low-income housing recovery class, depending on its nature and the date it was placed in service. The unadjusted basis of the asset (generally its cost) is recovered over the period reflected by its recovery class, although the taxpayer can elect a longer recovery period.
Under the bonus depreciation rules, a taxpayer may deduct in the property’s placed-in-service year, rather than capitalize and recover through MACRS, a percentage of the adjusted basis of qualified property. The adjusted basis of the property is reduced by the amount of this additional first-year depreciation (and by the amount of any first-year expensing under other code provisions, such as §179) before the MACRS deduction for the year in which the property is placed in service and subsequent years is computed.