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Cost segregation is a tax analysis that identifies portions of a building acquisition or improvement that should be classified as shorter-life personal property or land improvements, rather than 39-year nonresidential real property. For a newly acquired commercial property, that reclassification can accelerate deductions and reduce current tax liability.
In practice, a cost segregation study reviews construction components, engineering details, and tax classifications to separate assets such as certain dedicated electrical, plumbing, specialty finishes, and site improvements from the building shell.
Historically, the framework comes from Modified Accelerated Cost Recovery System (MACRS) under IRC § 168. Subsection 168(a) provides that depreciation is determined using the applicable method, recovery period, and convention. For nonresidential real property, Subsection 168(b)(3)(A) requires straight-line depreciation, and Subsection 168(c) assigns a 39-year recovery period. By contrast, many reclassified assets fall into 5-, 7-, or 15-year classes under § 168(e) and Rev. Proc. 87-56 principles summarized in the MACRS guidance.
Before the One Big Beautiful Bill Act (OBBBA), bonus depreciation under § 168(k) was phasing down for property acquired before January 20, 2025: 60% for 2024, 40% for 2025, and 20% for 2026. After OBBBA, 100% bonus depreciation was restored permanently for qualified property acquired after January 19, 2025. That change materially increases the value of a cost segregation study commercial real estate acquisition because more short-life components can now be fully deducted in the placed-in-service year, assuming all § 168(k) requirements are met.
OBBBA also added new § 168(n) treatment for Qualifying Production Property (QPP), a separate 100% expensing rule for certain nonresidential real property used in qualified production activities, effective for property placed in service after July 4, 2025. That rule is distinct from traditional commercial property tax depreciation and does not replace ordinary cost segregation analysis for most acquisitions.
The main takeaway is that cost segregation reduces tax burden by converting part of a building purchase into shorter-life assets eligible for faster depreciation and, now more often, full first-year expensing. The benefit is strongest when the analysis is technically sound, well documented, and aligned with § 168 classification rules. Because these determinations are highly technical, property owners should consult a qualified tax professional or cost segregation specialist before claiming accelerated depreciation benefits.
For more than four decades, Bennett Thrasher has provided businesses and individuals with strategic business guidance and solutions through professional tax, audit, advisory, and business process outsourcing services. Contact Trey Webb, partner in charge of Bennett Thrasher’s Real Estate and Hospitality Tax Group, or call us at 770.396.2200.
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