|
Note: Each chapter in this Audit Techniques
Guide can be printed individually. Please follow the links at the beginning or end
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Chapter 7.3 |
Table of Contents |
Chapter 7.5
November 28, 2005
MEMORANDUM FOR INDUSTRY DIRECTORS, LMSB DIRECTORS, FIELD
OPERATIONS DIRECTOR, FIELD SPECIALISTS DIRECTOR, PREFILING AND TECHNICAL
GUIDANCE AREA DIRECTORS, SBSE
FROM: /s/ Henry V. Singleton, Industry Director Retailers, Food,
Pharmaceuticals & Healthcare; /s/ Steve Burgess Director, Examination,
SBSE
SUBJECT: Field Directive on the Planning and Examination of Cost
Segregation Issues in the Biotech/Pharmaceutical Industry
Introduction
This memorandum is intended to provide direction to effectively utilize resources
in the classification and examination of a taxpayer who is recovering costs through
depreciation of tangible property used in the Biotech/Pharmaceutical Industry. This
Directive is not an official pronouncement of the law or the position of the Service
and cannot be used, cited or relied upon as such.
Background
The crux of cost segregation is determining whether an asset is I.R.C. §1245 property
(shorter cost recovery period property) or §1250 property (longer cost recovery
period property). The most common example of §1245 property is depreciable
personal property, such as equipment. The most common examples of §1250 property
are buildings and building components, which generally are not §1245 property.
The difference in recovery periods has placed the Internal Revenue Service and taxpayers
in adversarial positions in determining whether an asset is §1245 or §1250 property.
Frequently, this causes the excessive expenditure of examination resources.
The Director for the Retailers, Food, Pharmaceuticals and Healthcare Industry chartered
a working group to address the most efficient way to approach cost segregation issues
specific to the Biotech/Pharmaceutical industry. The group produced the attached
matrix and related definitions as a tool to reduce unnecessary disputes and foster
consistent audit treatment.
Planning and Examination Guidance
The Biotech/Pharmaceutical industry matrix recommending the categorization and general
depreciation system recovery period of various assets is attached as Exhibit A.
(For recovery periods under IRC §168(g) alternative depreciation system, see Revenue
Procedure 87-56, 1987-2 CB 674). If the taxpayer’s tax return position for
these assets is consistent with the recommendations in Biotech/Pharmaceutical matrix
(Exhibit A), examiners should not make adjustments to categorization and recovery
periods. If the taxpayer reports assets differently, then adjustments should
be considered. The Industry intends to update the Biotech/Pharmaceutical matrix
(Exhibit A) regularly.
See also the Cost Segregation Audit Techniques Guide. Refer especially to
Appendix Chapter 6.3, which provides examples and general rules for asset classification.
If you have any questions, please contact either Louis Milano, Technical Advisor,
Pharmaceuticals at 908-301-2106, Robert Lento, Engineering & Valuation Group
Manager at 908-301-2129, Milton Pagan, SBSE Senior Program Analyst at 619-615-9583,
or Ardell Mueller, Senior Program Analyst, Retailers, Food, Pharmaceuticals and
Healthcare Industry at 630-493-5946.
Back to Top
LMSB DIRECTIVE ON COST SEGREGATION IN THE BIOTECH /PHARMACEUTICAL INDUSTRY -
EXHIBIT A
This matrix, which is part of the Cost Segregation Audit Techniques Guide, is intended
to provide direction to effectively utilize resources in the classification and
examination of property used in the Biotech/Pharmaceutical industry. General
fact patterns specific to this industry have been considered in the classification
of these assets and may not be applicable to other industries. Similarly,
asset classification guidance issued for other industries is based on the general
fact pattern for that industry and may not be applicable to the Biotech/Pharmaceutical
industry. For example, for asset classification of restaurants located within
a pharmaceutical manufacturing plant, refer to the industry directive for restaurants.
For examination techniques and historical background related to this issue, refer
to the Cost Segregation Audit Techniques Guide.
CAUTION: In the case of certain leasehold improvement property,
the classifications in this directive are superseded to the extent that the American
Jobs Creation Act of 2004 modifies IRC Section 168. Thus, a 15-year
straight line recovery period should replace the recovery period shown in the following
matrix if the asset is “qualified leasehold improvement property" (as defined in
IRC Section 168(e)(6)) placed in service by the taxpayer after 10/22/04 and before
1/1/08.
|
Asset
|
Property Type
|
Description
|
Recovery Period
|
|
Awnings & Canopies
|
1245
|
Readily removable overhangs or coverings, often of canvas or plastic, used to provide
shade or cover over exterior doors or windows. Does not include canopies
that are an integral part of a building’s structural shell, such as in the casino
industry or over docks. See also Concrete Foundations & Footings and Loading
Docks.
|
Personal Property With No Class Life - 7 Years
|
|
Breakrooms / Pantries / Lunchrooms
|
1250
|
A space within the building used for employee breaks, lunches, etc.
|
Building or Building Component – 39 Years
|
|
Breakrooms / Pantries / Lunchrooms
|
1245
|
Equipment such as tables, chairs, dishwashers, stoves, ovens, microwaves, toasters,
coffee machines, refrigerators, and freezers.
|
Personal Property With No Class Life - 7 Years
|
|
Bridges & Tunnels
|
1250 / 1245
|
Depreciable improvements directly to or added to land, whether such improvements
are section 1245 or 1250. Includes bridges and tunnels and all construction
required for their completion (such as excavation, backfill, footings, foundations,
piers, stone base, paving, etc.).
|
00.3 - Land Improvements but see Note 2 for exceptions
|
|
Ceilings
|
1250
|
All interior ceilings regardless of finish or décor; e.g., drywall or plaster, acoustic,
suspended, (including hangers, frames, grids, and tiles or panels), decorative metal
or tin, plastic or decorative panels, clouds, etc. See also Clean Room /
Climate Controlled Areas.
|
Building or Building Component – 39 Years
|
|
Clean Room / Climate Controlled Areas
|
1250
|
Areas created by fully enclosed walls, floors, ceilings, wall and floor coverings,
doors, and windows. These are designed to remain in place indefinitely, require
substantial time and effort to construct or remove, and integrated into the building's
design. These areas are climate controlled for air cleanliness, or temperature
or humidity. See also HVAC, Electrical, Plumbing, Gas & Sewer, Ceilings,
Floors, Walls, Windows, Doors, Wall Coverings, and Floor Coverings.
|
Building or Building Component – 39 Years
|
|
Clean Room / Climate Controlled Areas - Special Equipment
|
1245
|
Special items installed to achieve a controlled environment (air cleanliness, temperature,
or humidity) and to operate the facilities in a clean room / climate controlled
area (such as special variable power outlets; electric power, air, and vacuum
lines; duct work; special air handling units and HEPA filters; refrigeration units,
steam boilers, and temperature controls). Does not include building systems
used in the operation or maintenance of the building or necessary to provide general
building services.
|
Personal Property -
Note 1
|
|
Computers
|
1245
|
Processors (CPU), direct access storage device (DASD), tape drives, desktop and
laptop computers, CRT, terminals, monitors, printers, and other peripheral equipment.
Excludes process equipment control systems and computers that are an integral part
of building structural components (e.g., fire detection, heating, cooling, or energy
management systems, etc.).
|
00.12 Information Systems – 5 Years
|
|
Concrete
|
1250
|
Foundations & Footings Foundations and footings necessary for the proper
setting of the building. Excavation and backfill for building foundations.
Excavation and backfill for special equipment foundations where contained within
the footprint of the building. Includes formwork, reinforcement, concrete
block, and pre-cast or cast-in-place work.
|
Building or Building Component – 39 Years
|
|
Concrete Foundations & Footings
|
1250
|
Foundations and footings for signs, light poles, and other land improvements (except
buildings). Includes excavation, backfill, formwork, reinforcement, concrete
block, and pre-cast or cast-in-place work.
|
00.3 - Land Improvements but see Note 2 for exceptions
|
|
Concrete Foundations & Footings
|
1245
|
A foundation, pad, or footing for machinery or equipment that is so specially designed
that it is in essence a part of the machinery or equipment. Any function as
a building component must be strictly incidental to the function as an essential
part of the item of machinery or equipment that necessitated the special design
of the foundation. Increased thickness alone is not sufficient to show that
the foundation, pad, or footing is so specially designed that it is in essence a
part of the machinery or equipment it supports. Excavation and backfill are not
included where the foundation, pad, or footing is contained within the footprint
of the building. Includes formwork, reinforcement, concrete block, and pre-cast
or cast-in-place work.
|
Personal Property -
Note 1
|
|
Data Handling Equipment
|
1245
|
Adding and accounting machines, calculators, copiers, and duplicating machines.
Excludes computers and computer peripheral equipment. See also Computers.
|
00.13 Data Handling Equipment, except Computers – 5 Years
|
|
Doors
|
1250
|
Interior and exterior doors, regardless of decoration (including but not limited
to, double opening doors, overhead doors, revolving doors, entrance security gates,
or fire doors) and associated hardware (such as doorknobs, closers, kick plates,
hinges, locks, automatic openers, etc.).
|
Building or Building Component – 39 Years
|
|
Electrical
|
1250
|
All components of a building's or other inherently permanent structure's electrical
distribution system(s) used in the operation or maintenance of the building or necessary
to provide general building services (such as lighting, heating, ventilation, air
conditioning, etc.), electrical outlets of general applicability and accessibility,
and electrical wiring.
|
Building or Building Component – 39 Years
|
|
Electrical
|
1245
|
Special electrical connections which are necessary to and used directly with a specific
item of machinery or equipment or connections between specific items of individual
machinery or equipment; such as dedicated electrical outlets, wiring, conduit, and
circuit breakers by which machinery and equipment is connected to the building's
or other inherently permanent structure's electrical distribution system(s).
Does not include electrical outlets of general applicability and accessibility.
See Chapter 5 of the Cost Segregation Audit Techniques Guide for allocation examples.
|
Personal Property -
Note 1
|
|
Electrical - Light Fixtures - Exterior
|
1250
|
Exterior lighting whether decorative or not is considered section 1250 property
to the extent that the lighting relates to the operation or maintenance of the building.
This category includes building mounted lighting to illuminate walkways, entrances,
parking, etc.
|
Building or Building Component – 39 Years
|
|
Electrical - Light Fixtures - Exterior
|
1245
|
Lighting that highlights only the landscaping or building exterior (but not parking
areas or walkways) and does not relate to the operation or maintenance of the building.
|
Personal Property With No Class Life - 7 Years
|
|
Electrical - Light Fixtures - Exterior .
|
1250 / 1245
|
Pole mounted or freestanding outdoor lighting system to illuminate sidewalks, parking
or recreation areas See also Poles & Pylons
|
00.3 - Land Improvements but see Note 2 for exceptions
|
|
Electrical - Light Fixtures - Interior
|
1250
|
Includes lighting such as recessed and lay-in lighting, night lighting, and exit
lighting, as well as decorative lighting fixtures that provide substantially all
the artificial illumination in the building or along building walkways. For
emergency and exit lighting, see Fire Protection & Alarm Systems.
|
Building or Building Component – 39 Years
|
|
Electrical - Light Fixtures - Interior
|
1245
|
Light fixtures, such as neon, track lighting, or grow lights which are decorative
in nature and not necessary for the operation or maintenance of the building.
If the decorative lighting were turned off, the other sources of lighting would
provide sufficient light for operation or maintenance of the building. If
the decorative lighting is the primary source of lighting, then it is section 1250
property.
|
Personal Property With No Class Life - 7 Years
|
|
Electrical - Light Fixtures - Special Use
|
1245
|
Special light fixtures which are necessary to and used directly with a specific
item of machinery or equipment, manufacturing process, or research and experimentation
activity. Does not include light fixtures that relate to the operation or
maintenance of the building.
|
Personal Property -
Note 1
|
|
Elevators & Escalators
|
1250
|
Elevators and escalators, including all components thereof (e.g., handrails and
smoke baffles), which are permanently affixed to the building and designed to remain
in place. They relate to the operation or maintenance of the building and
are structural components.
|
Building or Building Component – 39 Years
|
|
Energy Management Systems
|
1250
|
Energy management systems to monitor or maximize the efficiency of building systems
(such as HVAC, lighting, fire protection and security systems) by starting and stopping
the systems, raising and lowering temperatures, regulating dampers and valves, adjusting
lighting levels, alerting employees to problems, etc. Includes detection devices
such as smoke, motion, and infrared devices, photocells, foil and contact switches,
pressure switches, proximity alarms, sensors, alarm transmitting controls, data
gathering panels, demand controllers, thermostats, computer controls, outside air
economizers, occupancy sensors, electronic ballasts, and all related wiring and
conduit.
|
Building or Building Component – 39 Years
|
|
Energy Management Systems
|
1245
|
Energy management systems to monitor or maximize the efficiency of non-building
systems by starting and stopping process equipment, regulating equipment air handlers,
detecting chemical leaks or equipment operating temperatures, monitoring power quality,
etc. Includes sensors, alarm transmitting controls, data gathering panels,
demand controllers, thermostats, computer controls, outside air economizers, and
related wiring and conduit for the non-building energy management system.
|
Personal Property -
Note 1
|
|
Fencing, Retaining Walls, Screen Walls, Fountains & Other Land Improvements.
|
1250 / 1245 |
Depreciable improvements directly to or added to land, whether such improvements
are section 1245 or 1250 property. Examples include fences; canals; waterways;
drainage facilities; sewers (not including municipal sewers in Class 51); retaining
walls; water falls and fountains; holding, settling, or detention ponds; and irrigation
systems.
|
00.3 - Land Improvements but see Note 2 for exceptions |
|
Fire Protection & Alarm Systems
|
1250
|
Fire protection and alarm systems for the protection of the building. Includes
sensing devices, computer controls, sprinkler heads, associated piping or plumbing,
pumps, visual and audible alarms, alarm control panels, heat and smoke detection
devices, fire escapes, fire doors, emergency exit lighting and signage, and cabinets
(regardless of mounting) holding fire fighting equipment such as fire extinguishers,
fire hoses, etc.
|
Building or Building Component – 39 Years
|
|
Fire Protection Equipment
|
1245
|
Special fire detection or suppression systems (such as Halon or Carbon Dioxide,
etc.) directly associated with a piece of equipment or process. Fire extinguishers
and related fire extinguisher cabinets designed and used for protection against
a particular hazard created by a business activity. See Restaurant Industry
Directive for restaurants, cafeterias, or other commercial food preparation areas.
|
Personal Property -
Note 1
|
|
Floor Coverings
|
1250
|
Floor covering affixed with permanent adhesive, nailed, or screwed in place.
Includes marble, paving brick, ceramic or quarry tile, and other coverings cemented,
mudded, or grouted to the floor; vinyl composition tile (VCT), sheet vinyl, carpeting,
or wood attached with permanent adhesive, nails, or screws; and paint, epoxy, coatings
and sealers directly applied to the floor.
|
Building or Building Component – 39 Years
|
|
Floor Coverings
|
1245
|
Floor covering that is installed by means of strippable adhesives and can be 1)
readily removed and remain in substantially the same condition after removal as
before, or 2) moved and reused, stored, or sold in its entirety.
|
Personal Property -
Note 1
|
|
Floors
|
1250
|
Includes concrete slabs and other floor systems. Floors include special treatments
applied to or otherwise a permanent part of the floor. For example "super
flat" finish, sloped drainage basins, raised perimeter, cooler, freezer and garbage
room floors. Does not include special foundations - see Concrete Foundations
& Footings.
|
Building or Building Component – 39 Years
|
|
Floors
|
1245
|
Raised false floors located in a limited area and installed over an existing floor
to accommodate specific equipment. Such floors are a necessary part of the
installation and operation of the specific equipment they accommodate. Removal
of these floors does not result in extensive renovations or loss of functionality
within the building.
|
Personal Property -
Note 1
|
|
Gas & Sewer
|
1250
|
All components of a building's or other inherently permanent structure's natural
gas distribution system and sewer collection system used in the operation or maintenance
of the building or necessary to provide general building services, e.g., hot water
and hot air (natural gas) and waste removal (sewer).
|
Building or Building Component – 39 Years
|
|
Gas & Sewer
|
1245
|
Special natural gas and sewer connections which are necessary to and used directly
with a specific item of machinery or equipment or connections between specific items
of individual machinery or equipment. Includes dedicated piping, valves, and
hook-ups by which machinery and equipment are connected to the building's or other
inherently permanent structure's natural gas distribution system(s) or sewer collection
system(s). Does not include natural gas or sewer connections of general applicability
and accessibility.
|
Personal Property -
Note 1
|
|
Gas & Sewer - Special Gas Systems
|
1245
|
Special gas systems separate from the building's or other inherently permanent structure's
natural gas system which are used in a manufacturing process or research and experimentation
activity. Special gas would include carbon dioxide, pure oxygen, nitrogen,
argon, etc. Includes filters, tanks, pumps, specialized piping, valves, and
end use connections.
|
Personal Property -
Note 1
|
|
Gas & Sewer - Special Waste Systems
|
1245
|
Special waste or sewer systems separate from the building's or other inherently
permanent structure's sewer collection system which are used in a manufacturing
process or research and experimentation activity. Special waste would include
toxic, bio-hazard, nuclear, and medical. Includes filters, tanks, pumps, specialized
piping and valves.
|
Personal Property -
Note 1
|
|
Heating, Ventilating, Air Conditioning (HVAC)
|
1250
|
All components of a building's or other inherently permanent structure's central
heating, ventilating and air conditioning distribution system(s) used in the operation
or maintenance of the building or necessary to provide general building services
such as forced cool and hot air, ventilation, ductwork, air handlers, exchangers,
baffles. HVAC systems that are installed not only to meet the temperature
and humidity requirements of machinery, but are also installed for additional significant
purposes, such as employee comfort and ventilation, are building components.
|
Building or Building Component – 39 Years
|
|
Heating, Ventilating, Air Conditioning (HVAC)
|
1245
|
Special and separate HVAC units that meet the sole justification test are included
(i.e., machinery the sole justification for the installation of which is the fact
that such machinery is required to meet temperature or humidity requirements which
are essential for the operation of other machinery or the processing of materials
or used in connection with research or experimentation). HVAC may meet the
sole justification test even though it incidentally provides for the comfort of
employees, or serves, to an insubstantial degree, areas where such temperature or
humidity requirements are not essential. Includes refrigeration units, condensers,
compressors, accumulators, coolers, pumps, connecting pipes, and wiring for the
mechanical equipment for climate controlled rooms, walk-in freezers, and coolers.
See also Clean Room / Climate Controlled Areas. Allocation of HVAC is
not appropriate.
|
Personal Property -
Note 1
|
|
HVAC - Hot or Chilled Water Systems
|
1250
|
All components of a building's or other inherently permanent structure's hot or
chilled water system(s) used in the operation or maintenance of the building or
necessary to provide general building services associated with the heating, ventilating,
and air conditioning system(s). Includes boilers, chillers and cooling towers,
pumps, valves, heat exchangers, air handling units, piping (both source and return),
etc. See also Heating, Ventilating, Air Conditioning (HVAC).
|
Building or Building Component – 39 Years
|
|
Industrial Steam & Electric Generating Systems
|
1250 / 1245
|
Depreciable assets, whether such assets are section 1245 property or 1250 property,
used in the production and/or distribution of electricity with rated total capacity
in excess of 500 Kilowatts and/or assets used in the production and/or distribution
of steam with rated total capacity in excess of 12,500 pounds per hour for use by
the taxpayer in its industrial manufacturing process or plant activity and not ordinarily
available for sale to others. Does not include buildings and structural components
as defined in section 1.48-1(e) of the regulations. See Asset Class
|
00.4 in Rev. Proc. 87-56. 00.4 Industrial Steam and Electric Generation and/or
Distribution Systems - 15 Years
|
|
Interstitial Areas, Catwalks and Mezzanines
|
1250
|
Interstitial areas created by fully enclosed decks and walls between functional
floors of a building, catwalks and mezzanines that provide access to various sections
or levels of the building, or provide more than incidental working space.
Designed to remain in place indefinitely, require substantial time and effort to
construct or remove and integrated into building design.
|
Building or Building Component – 39 Years
|
|
Interstitial Areas, Catwalks and Mezzanines
|
1245
|
Interstitial areas created by fully enclosed decks and walls between functional
floors of a building, catwalks and mezzanines designed and constructed only to provide
access to inspect, repair, or operate specific items of machinery or equipment.
|
Personal Property -
Note 1
|
|
Landscaping & Shrubbery
|
1250 / 1245
|
Depreciable improvements directly to or added to land, whether such improvements
are section 1245 or 1250 property. Examples include landscaping, shrubbery,
trees, and sod.
|
00.3 - Land Improvements but see Note 2 for exceptions
|
|
Loading Docks
|
1250
|
Bumpers, permanently installed dock levelers, plates, seals, lights, canopies, docks,
and overhead doors used in the receiving and shipping of supplies and raw materials,
work in process, and finished products inventories.
|
Building or Building Component – 39 Years
|
|
Machinery & Equipment
|
1245
|
Tangible personal property, not covered elsewhere, which is in the nature of machinery
or equipment. Includes a structure which is essentially an item of machinery
or equipment if the use of the structure is so closely related to the use of such
property that the structure clearly can be expected to be replaced when the property
it initially houses is replaced. Factors which indicate that a structure is
closely related to the use of the property it houses include the fact that the structure
is specifically designed to provide for the stress and other demands of such property
and the fact that the structure could not be economically used for other purposes.
Includes such structures as oil and gas storage tanks, grain storage bins, silos,
fractionating towers, blast furnaces, basic oxygen furnaces, coke ovens, brick kilns,
and coal tipples. Does not include structural components of a building or
other inherently permanent structure. See also Plumbing; Electrical; Heating,
Ventilating, Air Conditioning (HVAC); and Elevators & Escalators.
|
Personal Property -
Note 1
|
|
Millwork
|
1250
|
General millwork is all building materials made of finished wood (e.g., doors and
frames, window frames, sashes, porch work, mantels, panel work, stairways, and special
woodwork). Includes pre-built wooden items brought to the site for installation
and items constructed on site (such as restroom cabinets, door jambs, moldings,
trim, etc.).
|
Building or Building Component – 39 Years
|
|
Millwork
|
1245
|
Decorative millwork is the decorative finish carpentry in a building. Examples
include detailed crown moldings, and lattice work placed over finished walls or
ceilings. The decorative millwork serves to enhance the overall décor of the
building and is not related to the operation of the building. Excludes cabinets
and counters in a restroom. See also Restroom Accessories.
|
Personal Property With No Class Life - 7 Years
|
|
Office Furnishings
|
1245
|
Desks, chairs, credenzas, file cabinets, tables, bookcases, coat racks, projection
screens, and other office furniture such as workstations. Also includes telephone
equipment, fax machines, and other communications equipment. Does not include
communications equipment included in other asset classes in Rev. Proc. 87-56.
|
00.11 Office Furniture, Fixtures, and Equipment – 7 Years
|
|
Parking Lots
|
1250 / 1245
|
Depreciable improvements directly to or added to land, whether such improvements
are section 1245 or 1250. Grade level surface parking and base area usually constructed
of asphalt, brick, concrete, stone or similar material. Also includes bumper
blocks, curb cuts, curb work, striping, concrete landscape islands, truck parking
ramps and staging areas, and traffic control systems (such as traffic lights and
detectors, card readers, parking equipment, etc.). See also Roadways.
|
00.3 - Land Improvements but see Note 2 for exceptions
|
|
Parking Structures
|
1250
|
Any structure or edifice the purpose of which is to provide parking space.
Includes garages, parking ramps, or other parking structures.
|
Building or Building Component – 39 Years
|
|
Plumbing
|
1250
|
All components of a building's or other inherently permanent structure's plumbing
distribution system(s) used in the operation or maintenance of the building or necessary
to provide general building services such as drains, valves, water flow switches,
restroom plumbing fixtures (e.g., toilets) and piping, electric water coolers, and
sprinkler mains and heads. See also Gas & Sewer.
|
Building or Building Component – 39 Years
|
|
Plumbing
|
1245
|
Special plumbing connections which are necessary to and used directly with a specific
item of machinery or equipment or connections between specific items of individual
machinery or equipment. Includes dedicated piping, valves, and hook-ups by
which machinery and equipment is connected to the building's or other inherently
permanent structure's plumbing distribution system(s). Does not include plumbing
hook-ups of general applicability and accessibility.
|
Personal Property -
Note 1
|
|
Plumbing - Special Water Systems
|
1245
|
Special water systems separate from the building's or other inherently permanent
structure's plumbing systems which are used to produce specialty water such as deionized
water (DI) or water for injection (WFI) which is required in a manufacturing process
or research and experimentation activity. Includes filters, tanks, pumps,
specialized piping, valves, and end use connections.
|
Personal Property -
Note 1
|
|
Poles & Pylons
|
1250 / 1245
|
Poles made of metal or similar material usually set in concrete footings or bolt-mounted
to concrete piers. Their use is for supporting parking area lights, signage,
flags, etc. Pylons made of concrete, brick, wood frame and stucco, or similar
materials usually set in the ground or on a concrete foundation, and usually used
for signage. Note* asset class 00.3 Land improvements includes both section
1245 and 1250 property per Rev. Proc. 87-56. See also Signs and Electrical
– Light Fixtures – Exterior.
|
00.3 - Land Improvements but see Note 2 for exceptions
|
|
Restaurant / Cafeteria - In Facility
|
|
Facilities that include a restaurant, cafeteria or other commercial food preparation
property such as a deli or snack bar.
|
See Restaurant Industry Directive
|
|
Restroom Accessories
|
1250
|
Paper towel dispensers, electric hand dryers, towel racks or holders, cup dispensers,
purse shelves, toilet paper holders, soap dispensers or holders, lotion dispensers,
sanitary napkin dispensers and waste receptacles, coat hooks, handrails, grab bars,
mirrors, shelves, vanity cabinets, counters, ashtrays, and other items that are
built into or mounted on walls or partitions.
|
Building or Building Component – 39 Years
|
|
Restroom Partitions
|
1250
|
Shop made and standard manufacture toilet partitions.
|
Building or Building Component – 39 Years
|
|
Retail Store - In Facility
|
|
A retail store or employee outlet, used to sell merchandise (such as company products,
newspapers, magazines, film and digital images, etc.).
|
See Retail Industry Directive
|
|
Roadways
|
1250 / 1245
|
Depreciable improvements directly to or added to land, whether such improvements
are section 1245 or 1250. Grade level driveways, roads, and base areas usually
constructed of asphalt, brick, concrete, stone or similar material. Also includes
guard rails, curb cuts, and curb work.
|
00.3 - Land Improvements but see Note 2 for exceptions
|
|
Roof
|
1250
|
All elements of the roof including but not limited to joists, rafters, deck, shingles,
vapor barrier, skylights, trusses, girders, and gutters. Determination of
whether decorative elements of a roof (e.g., false dormers, mansard) constitute
structural building components depends on their integration with the overall roof,
not their load bearing capacity. If removal of the decorative element results
in the direct exposure of building components to water, snow, wind, or moisture
damage, or if the decorative element houses lighting fixtures, wiring, or other
structural components, then the decorative elements are part of the overall roof
system and are structural components of the building.
|
Building or Building Component – 39 Years
|
|
Security Systems
|
1250
|
Security equipment for the protection of the building (and its contents) from burglary
or vandalism and protection of employees from assault. Examples include window
and door locks; card key access systems; keyless entry systems; security cameras,
recorders, monitors and related equipment; perimeter and interior building motion
detectors; security lighting; alarm systems; and security system wiring and conduit.
|
Building or Building Component – 39 Years
|
|
Security Systems
|
1245
|
Electronic surveillance systems used to track and monitor tangible items, e.g.,
raw materials, work in process, and finished products inventories. Includes
scanners, electronic gates, surveillance cameras, recorders, monitors and related
equipment.
|
Personal Property -
Note 1
|
|
Sidewalks & Curbs
|
1250 / 1245
|
Depreciable improvements directly to or added to land, whether such improvements
are section 1245 or 1250. Sidewalks and curbs are usually constructed of concrete,
asphalt, stone or similar material.
|
00.3 - Land Improvements but see Note 2 for exceptions
|
|
Signs
|
1250
|
Exit signs, restroom identifiers, room numbers, fire lanes, building identification,
and other signs relating to the operation or maintenance of a building.
|
Building or Building Component – 39 Years
|
|
Signs
|
1245
|
Interior signs used to display directories of names, departments, etc. Not
related to the operation or maintenance of a building. Exterior signs used
to display names, symbols, directions, etc. For pylon signs, includes only
the sign face and related dedicated wiring. See also Poles & Pylons.
|
Personal Property With No Class Life - 7 Years
|
|
Site Preparation, Grading & Excavation
|
N/A
|
Nondepreciable land preparation costs, in general, include the one time cost of
demolition, clearing and grubbing, blasting, site stripping, fill or excavation,
dewatering, and grading to allow development of land. Clearing and grubbing
is the removal of debris, brush, trees, etc. from the site. Stripping is the
removal of the topsoil to provide a stable surface for site and building improvements.
The grading of land involves moving soil for the purpose of producing a more level
surface to allow development of the land. These costs would not have to be
reincurred if the building was repaired, rebuilt, or even torn down and replaced
with some other type of building.
|
Land - Not Depreciable
|
|
Site Preparation, Grading & Excavation
|
1250
|
Depreciable clearing, grading, excavating and removal costs directly associated
with and necessary for the proper setting of the building and building components
are part of the cost of construction of the building. See also Concrete Foundations
& Footings.
|
Building or Building Component – 39 Years
|
|
Site Preparation, Grading & Excavation
|
1250
|
Depreciable clearing, grading, excavating and removal costs directly associated
with the construction of sidewalks, parking areas, roadways and other depreciable
land improvements are part of the cost of construction of the improvements.
|
00.3 - Land Improvements but see Note 2 for exceptions
|
|
Site Utilities
|
1250
|
Site utilities begin where the responsibility rests with the taxpayer and not the
utility company which is providing the service. Site utilities end at either
a building or other permanent structure. Site utilities also include any distribution
systems between buildings or other permanent structures. The cost of the site
utilities would not have to be reincurred if the building or other permanent structure
was repaired, rebuilt, or even torn down and replaced with some other type of building.
Typically the utilities provided would be electricity, natural gas, water, sewer,
and steam. See also Electrical, Plumbing, and Gas & Sewer.
|
Building or Building Component – 39 Years
|
|
Site Utilities
|
1250
|
Drainage facilities and sewers that are not municipal sewers.
|
00.3 - Land Improvements but see Note 2 for exceptions
|
|
Sound Systems
|
1245
|
Equipment and apparatus, including wiring, used to provide amplified sound or music
(e.g., public address by way of a paging system or background music). Excludes
applications linked to fire protection and alarm systems.
|
Personal Property With No Class Life - 7 Years
|
|
Trash Enclosures
|
1250
|
Enclosures attached to the building for waste receptacles. Typically constructed
of the same materials as the building shell with either interior or exterior access.
These trash enclosures are an integral part of the building shell and cannot be
moved without damage to the underlying building.
|
Building or Building Component – 39 Years
|
|
Trash Enclosures
|
1250
|
Freestanding enclosures, typically constructed on a concrete pad with its posts
set in the concrete, for waste receptacles. Serves both safety and decorative
functions.
|
00.3 - Land Improvements but see Note 2 for exceptions
|
|
Wall Coverings
|
1250
|
Includes interior and exterior paint; ceramic or quarry tile, marble, stone, brick,
and other finishes affixed with mortar, cement, or grout; paneling, wainscoting,
and other wood finishes affixed with nails, screws, or permanent adhesives; sanitary
finishes such as Fiberglass Reinforced Plastic (FRP), stainless steel, or plastic;
sound absorbing or fabric wall panels; and wall protection (such as bumpers, corner
guards, etc.).
|
Building or Building Component – 39 Years
|
|
Wall Coverings
|
1245
|
Strippable wallpaper that causes no damage to the underlying wall or wall
surface.
|
Personal Property With No Class Life - 7 Years
|
|
Walls - Exterior
|
1250
|
All exterior walls and building support regardless of construction materials.
Exterior walls may include columns, posts, beams, girders, curtain walls, tilt up
panels, studs, framing, sheetrock, insulation, windows, doors, exterior façade,
brick, masonry, etc.
|
Building or Building Component – 39 Years
|
|
Walls - Interior
|
1250
|
All load bearing interior partitions regardless of construction. Also includes
non-load bearing partitions regardless of height (typically constructed of studs
and sheetrock or other materials) that divide or create rooms or provide traffic
control. Includes rough carpentry and finishes such as plaster, dry wall,
gypsum board, concrete block, glass, or metal.
|
Building or Building Component – 39 Years
|
|
Walls - Interior
|
1245
|
Interior walls where the partition can be 1) readily removed and remain in substantially
the same condition after removal as before, or 2) moved and reused, stored, or sold
in their entirety.
|
Personal Property With No Class Life - 7 Years
|
|
Window Treatments
|
1245
|
Window treatments which are readily removable such as drapes, curtains, louvers,
blinds, post construction tinting, etc.
|
Personal Property With No Class Life - 7 Years
|
|
Windows
|
1250
|
Exterior and interior windows.
|
Building or Building Component – 39 Years
|
Back to Top
NOTES
Note 1: The recovery period depends on the use of the property.
See the Cost Segregation Audit Techniques Guide Appendix Chapter 6.3 for examples
and application of the asset classification rules of Revenue Procedure 87-56 activity
classes 01.1 to 80.0 or "Certain Property for Which Recovery Periods Assigned" letters
A through E at the end of Revenue Procedure 87-56.
Note 2: Land improvements are included in some activity classes
in Revenue Procedure 87-56. See the Cost Segregation Audit Techniques Guide
Appendix Chapter 6.3 for examples and application of the asset classification rules
of Revenue Procedure 87-56.
CAUTION: In the case of certain leasehold improvement property,
the classifications in this directive are superseded to the extent that the American
Jobs Creation Act of 2004 modifies IRC Section 168. Thus, a 15-year
straight line recovery period should replace the recovery period shown in the above
matrix if the asset is “qualified leasehold improvement property" (as defined in
IRC Section 168(e)(6)) placed in service by the taxpayer after 10/22/04 and before
1/1/08.
Chapter 7.3 |
Table of Contents |
Chapter 7.5
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