©2014 tax savings. delivered. cost segregation - tpr implementation the implementation of the...

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©2014 Tax Savings. Delivered. Cost Segregation - TPR Implementation The Implementation of the Tangible Property Regulations Cost Segregation Services, Inc. Copyright © 2014 The Role of Cost Segregation

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Page 1: ©2014 Tax Savings. Delivered. Cost Segregation - TPR Implementation The Implementation of the Tangible Property Regulations Cost Segregation Services,

©2014

Tax Savings. Delivered. Cost Segregation - TPR Implementation

The Implementation of theTangible Property Regulations

Cost Segregation Services, Inc. Copyright © 2014

The Role of Cost Segregation

Page 2: ©2014 Tax Savings. Delivered. Cost Segregation - TPR Implementation The Implementation of the Tangible Property Regulations Cost Segregation Services,

©2014

Tax Savings. Delivered. Cost Segregation - TPR Implementation

When was the last time you didsomething for the 1st time?

Research

Contact Trusted Advisor

Experienced Advisor

AnalysisRecommend

Implementation

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Tax Savings. Delivered. Cost Segregation - TPR Implementation

TPR Implementation Cycle

CSSIResource

Guide Friend Trusted Advisor

Cost Segregation Professional

Advisor

Preliminary Analysis

Recommend Process

Implementation

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©2014

Tax Savings. Delivered. Cost Segregation - TPR Implementation

Bio

Page 5: ©2014 Tax Savings. Delivered. Cost Segregation - TPR Implementation The Implementation of the Tangible Property Regulations Cost Segregation Services,

©2014

Tax Savings. Delivered. Cost Segregation - TPR Implementation

Capitalize or Expense?Welcome to the Tangible Property Regs

General framework for distinguishing

Capital Expenditures from:• Supplies• Repairs• Maintenance

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Tax Savings. Delivered. Cost Segregation - TPR Implementation

Capitalize or Expense?Welcome to the Tangible Property Regs

• 10 yrs. 300+ Pages

• Acquire, Produce, Improve Tangible Property

• Not Many Bright Lines

• Lots of Examples

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Tax Savings. Delivered. Cost Segregation - TPR Implementation

You Need to: Make Your Clients Aware… Before it’s TOO LATE

• Advantage to write off Late Partial Dispositions.

• “Use It or Lose it” Deadlines in tax year 2014?

• Need a Capitalization Policy for tangible property less than $500 per invoice by … January 1, 2014

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Tax Savings. Delivered. Cost Segregation - TPR Implementation

Today’s AgendaActions to Take

• Overview of the Regulations- Resource Documents.

• Greatest Impact to Tax Professionals.

• How to: Applying Partial Disposition.

• Cost Segregation and how it helps in applying TPR.

• Improvement Standards Basics for UOP.

• Safe Harbors for your clients.

Page 9: ©2014 Tax Savings. Delivered. Cost Segregation - TPR Implementation The Implementation of the Tangible Property Regulations Cost Segregation Services,

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Tax Savings. Delivered. Cost Segregation - TPR Implementation

ResearchHow to Implement the TPRs

Page 10: ©2014 Tax Savings. Delivered. Cost Segregation - TPR Implementation The Implementation of the Tangible Property Regulations Cost Segregation Services,

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Tax Savings. Delivered. Cost Segregation - TPR Implementation

Request These Resource Docs

CCH - Executive SummariesAICPA 6 Page Bullet Summary

Index of Examples in Fed RegisterQuestions and Answers

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AICPA Resources: Summary ChartWritten Policy Template - Webcast

• This is the most concise summary of the regulations in the industry. Six pages in bullet form. You will want to print this and keep it as a document to refer to when reading other articles.

• If you only look at one, this is the one to look at. “5 Stars” *****

Quick Summary Chart of Final TPR

• Great Overview of the TPR that discusses the difficulties of implementation.• Circular 230 Implications for Tax Professionals - discusses compliance risks.

Implementing the new TPR – Journal of

Accountancy

• OMG! You just found out that your client needs a Capitalization Policy in Place starting January 1 to be eligible for the De minimis Rule Safe Harbor.

• This document is priceless if your client does not have this in place already. Look under “Sample Written Book Capitalization Policy”. 5 stars*****

Written Policy Template from AICPA

• AICPA Webcast • A two hour presentation that provides insight on the new rules• Aired Oct. 23, 2013• Webinar at “Final Repair Regulations Dissected” Link

Final Repair Regulations Dissected

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Tax Savings. Delivered. Cost Segregation - TPR Implementation

Journal of AccountancyImplementing the New Tangible Property Regulations

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Journal of AccountancyImplementing the New Tangible Property Regulations

• “These rules will affect every TP that uses Tangible Property in its business…”

• “The rules are all-encompassing and complex…”

• “TP may need to devise new collection procedures to capture the necessary data to implement these regulations.”

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Journal of AccountancyImplementing the New Tangible Property Regulations

• “Circular 230 may present challenges to practitioners in signing tax returns of clients that have not implemented the final regulations.”

• “Due to the challenges of the regulations, waiting to address these issues until completing the 2014 tax return is ill-advised.”

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Tangible Property RegulationsResource Guidance on Deductions & Capitalization

Table of Contents

Materials and Supplies Examples

De minimis Rule Safe Harbor Examples

Routine Maintenance Safe Harbor Examples

Small Taxpayer Safe Harbor Examples

Betterment Examples

Adaptation Examples

Restoration Examples

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Tangible Property RegulationsResource Guidance on Deductions & Capitalization

©2014

Tax Savings. Delivered. Cost Segregation - TPR Implementation

Page 17: ©2014 Tax Savings. Delivered. Cost Segregation - TPR Implementation The Implementation of the Tangible Property Regulations Cost Segregation Services,

Tangible Property RegulationsResource Guidance on Deductions & Capitalization

©2014

Tax Savings. Delivered. Cost Segregation - TPR Implementation

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Tangible Property RegulationsGeneral Framework

Materials and Supplies

Cost to Acquire Tangible Property

Cost to Improve Tangible Property

Dispositions

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DispositionsBenefit to your Client

Section 168• Includes:– Sale or Exchange– Retirement– Physical Abandonment– Destruction– Transfer to supplies or scrap– Involuntary conversion– Retirement of a structural component

of (or improvement to) a building.

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DispositionsBenefit to your Client

Ability to write off assets that are no longer in use with Partial Disposition Election• Renovations• Remodels • Replacements• Abandoned in Place• Common Items – Roofs, HVAC, Electrical

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DispositionsCatch Up Provision

• Know the Value of what went into the Dumpster.

• Relative to the value that your client paid for the building.

• Disposed of as a Partial Disposition.

• Write down to the basis of the property in year 2014.

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DispositionsBenefit to your Client

Partial Disposition Election 1.168(i)-8(d)(2)

• PAST YEARS: Requires Change in Accounting Method Form 3115 and 481(a) adjustment to “catch up” (196).

• CURRENT & FUTURE YEARS: The election is made in the taxable year that the disposition occurs starting in 2014 and for new properties purchased.

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Dispositions

Example: A business owner buys 20 year old building and replaces the Roof after 5 years of ownership.

Old Regs: 5 years 39 years

Cost of Roof Hidden in Building Asset Basis

Roof 2 added asset

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Dispositions

Example: A business owner buys 20 year old building and replaces the Roof after 5 years of ownership.

New Regs: 5 years 39 years

Original Building Asset

New Roof Asset

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Dispositions

Example: • $1.5 m Nursing Home with

major renovations

• $91k in assets removed = Asset Valuation Study

• $31k in cash flow

• Basis Write Down

• Tax Savings at Sale 5 yr. property (35-41%) recaptured at Capital Gains Rate (20%)

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DispositionsRole of Cost Segregation

Page 27: ©2014 Tax Savings. Delivered. Cost Segregation - TPR Implementation The Implementation of the Tangible Property Regulations Cost Segregation Services,

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DispositionsRole of Cost Segregation

Example: • Asset Valuation - $53k• Cost Segregation on

Renovation - $126k

Year of “Opt In” Matters• 2013, 2014 Get Both• 2015 No Past Disposition:

Lose $53K

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Dispositions Tax Professionals Ask

#1 QuestionHow do I get “The Number”?

IRS says to use:• Reasonable Method• Cost Segregation is a Certain Method

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DispositionsReasonable Methods

Discounting the cost of the replacement asset to its placed-in-service year cost using the Consumer Price Index.

Appropriate for small projects, new equipment. Pro rata Allocation.

Both Methods need a valuation of the Unit of Property affected.

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DispositionsReasonable Methods

A Study allocating the cost of the asset to its individual components. This provides the proper valuation of the affected building assets.

“Cost Segregation is a certain method.”

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DispositionsCost Segregation Method

• Labor to Remove Materials• Disposal Fees• Identify Items Removed• Quantify Items• Value Items• Determine the remaining basis• Write Down of Basis is a

permanent tax reduction at the time of sale.

• Personal Property Sec 1245 35-40%• Real Property Section 1250 25%• Capital Gains 20%

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DispositionsCost Segregation Method

• Building Plans – Cost Detail Review

• IRS accepted Cost Allocation Methods

• Defined Engineering-based Methodology

• The Study: Report Form meets IRS Report Criteria

• Defendable

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DispositionsAsset Valuation Study

Works for all applications: • Large Renovations

• Complicated Remodels

• Retired Components and Partial Disposition

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Solution:It’s the Process

• Find all clients with depreciation on building assets.

• Qualify clients with estimated Disposition and Cost Segregation economic needs.

• Get an Engineering-based Study that meets the IRS’s guideline.

• Apply the Change in Accounting Method Form 3115 & 481(a) with study results to the client’s return.

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CPA Implementation Process

PartneringQualification

& Analysis

Client Contact

& Proposal

Execution

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Cost Segregation & Asset Valuations Expected Results of the CSSI Process

Ease of ComplianceCPA: 1-2 hrs per client

Timely completion

Client Satisfaction100%: Grateful for effort to save taxes

Additional Revenue

$1,000-$3,000 per client

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Recommendations: Take Action List

• Action Plan for Late Partial Disposition studies for 2014 tax year deadline.

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The process of analyzing and identifying commercial building components that are eligible for accelerated depreciation providing a significant tax benefit for the taxpayer.

Personal Property is Segregated from Real Property

$50k to $80k per $1 Million in CostWorks on $250k buildings

What is Cost Segregation?

Explaining Cost Segregation

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Explaining Cost Segregation

What is a Big Mac?

Straight-Line• Hamburger

Cost Segregation• 2 All Beef Patties• Special Sauce• Lettuce • Cheese• Pickles• Onions on a • Sesame Seed Bun

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Explaining Cost Segregation

Straight-Line

• Looks at the building as a Whole

• Structural Building Components

• Depreciated over 39yrs (27.5yrs)

• Real Property Only

Cost Segregation

• Identifies Parts and Pieces of the building

• Non-Structural Building Components

• Depreciated over 5, 7 & 15 years

• Personal Property & Real Property

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Explaining Cost SegregationUpgrade your Depreciation Strategy

Straight Line Cost Segregation

in HD

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Explaining Cost Segregation

5 & 7 Year Property Decorative building elements, wallpaper Specialty electrical, plumbing, mechanical Carpet, flooring, crown moldings, Built In cabinets, counter tops, millwork Security, special lighting, window treatments Communications, cable Kitchen fixtures, refrigeration equipment

15 Year Property Landscaping, paving, fencing, site utilities, parking

lot, signage, sidewalks, sprinklers, walkways

15 Year Property

5 & 7 YearProperty

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Explaining Cost Segregation

• An Engineering-Based Study of the building for tax purposes.

• Produce a Report that the Tax Professional submits with the return.

• Automatically accepted by IRS.

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Explaining Cost Segregation

Current Buildings Acquired after 1986

New Construction

New Acquisitions

Renovations / Leasehold Improvements

The Applications

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Explaining Cost Segregation Types of Commercial Buildings

• Apartment Complex, Condominium• Auto Dealership• Shopping Mall, Strip Center• Restaurant• Hotel/Motel• Medical/Dental/Veterinary Facilities/Surgical• Nursing Homes/Assisted Living• Office Buildings, Banks• Retail Chains/Franchises/Leasehold Space• Self Storage, Mini Warehouses• Supermarkets, Furniture Stores Etc…

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Information NeededTo Run Preliminary Analysis

• Depreciation Schedule is best

• What type of Building?• What did they pay for the building? (without the land)

• When did they purchase it?• Have there been any major renovations or

remodels?

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Cost SegregationProcess of Application

• Gather Documents for Engineers

• Completed in 4-6 weeks

• CPA will apply to return

• No need to Amend Past Tax Years

• Benefits start in next Quarter

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Cost Segregation vs.Straight-Line Depreciation

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Cost Segregation vs.Straight-Line Depreciation

Eighth Wonder of the World

Page 50: ©2014 Tax Savings. Delivered. Cost Segregation - TPR Implementation The Implementation of the Tangible Property Regulations Cost Segregation Services,

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Cost Segregation vs.Straight-Line Depreciation

Eighth Wonder of the World

Page 51: ©2014 Tax Savings. Delivered. Cost Segregation - TPR Implementation The Implementation of the Tangible Property Regulations Cost Segregation Services,

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Cost Segregation vs.Straight-Line Depreciation

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Financial Results of Cost Segregation

Dental OfficeBuilding Cost $ 250,176(with-out land)

Tax Savings Benefit: $32,845

Study Fee Before Tax: $2,420Study Fee After Tax: $1,549

ROI: 21:1

Project #9501

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Financial Results of Cost Segregation

Building Cost $324,000(with-out land)

Tax Savings Benefit: $52,856

Study Fee Before Tax: $3,400Study Fee After Tax: $2,176

ROI: 24:1

Office Condo

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Financial Results of Cost Segregation

Office/Warehouse

Building Cost $5,246,908(with-out land)

Tax Savings Benefit: $312,687

Study Fee Before Tax: $14,900Study Fee After Tax: $9,536

ROI: 33:1

Project # 9503

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Recommendations: Take Action List

• Late Partial Disposition study for 2014 tax year deadline.

• Cost Segregation Preliminary Analysis.

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Tangible Property RegulationsOpportunity & Issues

Scope Limitations: Temp and Final Allows for multiple 3115

Final Tangible RegulationsAutomatic Enrollment

2014 Final only

Correct Past Capitalization –Expense Issues / Disposition

Late Partial Disposition 2014 2014,Future: Automatic

Partial Disposition is an Annual ElectionIn the tax year item removed…Allows for duplicate assets in depreciation if no disposition taken

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Request These Resource Docs

CCH - Executive SummariesAICPA 6 Page Bullet Summary

Index of Examples in Fed RegisterQuestions and Answers

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Safe Harbor Issues

• De minimis Rule Safe Harbor Expenses (Action: Policy in place 1/1/14)

• Routine Maintenance Safe Harbor Expenses and Building Expenses

• Small Tax Payer Safe Harbor Expenses for Buildings

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Safe Harbors

De minimis Safe Harbor (Acquire or Produce) • Allows expensing of amounts paid to acquire or produce a

unit of real or personal property, including qualified materials and supplies.

• Calculated on an Invoice or Item level.

• Elected annually by including a statement with the taxpayer’s tax return for the year elected.

• Having an Applicable Financial Statement (AFS) makes a big difference on the limits that can be expensed.

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Cost to Acquire Tangible PropertyDe minimis Safe Harbor

• With AFS - $5,000 per invoice (or per item as substantiated by invoice)

• Written policy in place at beginning of year.• Policy to expense for amounts under a certain dollar amount or property

with an economic useful life of 12 months or less.• Treats the amounts as expenses on the AFS as well.

• Without AFS: - $500 per invoice (or per item as substantiated by invoice)

• Policy in place at beginning of year (written policy not required) for amounts under certain dollar amounts or property with an economic useful life of 12 months or less.

**Action Item: $5000 with AFS - Must have written expensing policies in place at the beginning of the tax year.

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AICPACapitalization Policy

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Materials and Supplies

• UOP with a useful life of < or = 12 months;• Fuel, lubricants, water, & similar items expected to be

consumed < or =12 months from beginning of use;• Costing $200 or less (up from $100 in temp regs).

Defined as tangible property used in taxpayer's business that is not inventory andA component acquired to maintain, repair, or improve a UOP that is not acquired as part of any single UOP.Reg Sec 1.162.-3Requires a Form 3115

You are now allowed to write off an individual supply if:

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Recommendations: Take Action List

• Late Partial Disposition study for 2014 tax year deadline.

• Cost Segregation Preliminary Analysis.

• Capitalization Policy in Place – AICPA Template.• De minimis Safe Harbor or Materials and Supplies.

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Cost to Improve Tangible PropertyRoutine Maintenance Safe Harbor Expenses

Buildings

• Deductible if you reasonably expect (at time UOP is placed in service) to perform more than once during the 10 year period from when the building system was placed in service.

• Safe Harbor does not apply to Betterments, Adaptations, or some Restorations (see Reg. § 1.263(a)-3(i)(3)).

• Consider-recurring nature of activity, industry practice, manufacturer’s recommendations, and TP’s business needs.

• Requires submission of Form 3115 to adopt.

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Cost to Improve Tangible PropertySmall Taxpayer Safe Harbor for Buildings

If your building has a cost basis of $1M or less, & less than $10M avg. annual income, a special rule applies:

• Can elect “not to apply” improvement rules to eligible buildings if the annual amount spent is less than $10,000 or 2% of unadjusted basis on a building-by- building basis.

• May be written off as repairs.• Example: $300k building = $6,000 limit• If limit is exceeded, does not apply to any amounts

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Recommendations: Take Action List

• Late Partial Disposition study for 2014 tax year deadline.

• Cost Segregation Preliminary Analysis. • Capitalization Policy in Place – AICPA Template.• De minimis Safe Harbor or Materials and Supplies.

• Routine Maintenance Safe Harbor Form 3115.• Small Taxpayer Safe Harbor Annual Election.

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Recommendations: Take Action List

• Rules of the Game have changed.• The Game has already started.• You need to know the rules to take advantage of the rules or minimize

the negative impact of the rules.• De minimis Rule $500/item deductible• You need to teach your client the rules. Dear Client letter.• Client should start tracking expenses differently.• Make your client aware of how difficult.• Multiple building sites – Multiple UOP.• 3115’s and 481(a) adjustment resources.• Summer Project• Shoe Box Client

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Cost to Improve Tangible PropertyImprovement Standards

Improvement Standards

• Deductible Repair • Capitalized Improvement

BAR TEST

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Cost to Improve Tangible PropertyImprovement Standards

Capitalize Improvements

BettermentsAdaptations Restorations

BAR TEST

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Cost to Improve Tangible PropertyImprovement Standards

Capitalize…Amounts paid for new building or improvements 1.263(a)-3.

- that increase value of property

- bring property to new or different use

- return of original condition

Expense... Amounts paid for incidental repairs and maintenance of property 1.263 (a)-1.

- keeps in ordinary operating conditionRefresh

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Capitalize

A Betterment is an expenditure that -• Corrects a Material Defect existing prior to the taxpayer’s acquisition

of the UOP or one that arose during the production of the UOP at acquisition or production;

• Is a Material Addition ( physical enlargement, expansion or extension) to the UOP;

• Is a Material Increase in capacity, strength, productivity, efficiency, quality, or output of the UOP.

Betterment-1.263 (a)-3(h)

Cost to Improve Tangible Property

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Capitalize

Lessee Improvements:• A lessee improvement constitutes a separate Unit of

Property from the leased property being improved, and must be capitalized.

• The new property interest is separate and identifiable from the lessor’s interest in the underlying property.

Cost to Improve Tangible Property

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Capitalize

• Must compare the condition of the property after the expenditure to the condition prior to the circumstances that necessitated the expenditure.

• Final regs specify the comparison rule only applies to wear, tear and damage that occurs during the use of the property.

• Compare to condition after last expense or original service date.

Cost to Improve Tangible Property

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Capitalize

• No bright line tests for material increase and additions.

• Material Increase Reg Example 21 • 50% reduction in energy and power cost from new insulation.

• Not a Material Increase Reg Example 20 • Indicates 10% efficiency and 20% additional capacity from changing 2

of 10 roof mounted HVAC units

Cost to Improve Tangible Property

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Capitalize

Adapting to New or Different UseChange not consistent: • With the taxpayer’s intended use • With the Unit of Property at the time originally placed in

service. (based on facts and circumstances)o Example: Drug Store to Walk in Medical Clinic.o Example: Hospital changes to Outpatient Surgery

Cost to Improve Tangible Property

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Capitalize

Cost to Improve Tangible Property

• Returns the UOP to its ordinarily efficient operating condition if the property has deteriorated to a state of disrepair and no longer functional.

• Results in rebuilding the property to like-new condition after the end of its class life.

• Is for the replacement of a part or combination of parts that comprise a major component or a substantial structural part of a UOP that perform a discreet and critical function.

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Capitalize

Cost to Improve Tangible Property

Major Component – Parts that perform a discrete and critical function in operation of UOP.

Substantial Structural Part - A large portion of the physical structure of the UOP.

Must consider all facts and circumstances - both quantitative & qualitative.

Not just the cost, but the size, type, function etc.

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Capitalize

Cost to Improve Tangible Property

“Not An Improvement” Examples in Regs• Roof Membrane Only (Reg Ex.15)

– Part vs. Whole Major Structural Component

• 100/300 Windows (25 % surface area)(Reg Ex.25)– Part vs. Whole Major Structural Component

• 3/10 Roof HVAC Units (Reg Ex.18) – 3 roof units vs. HVAC Building System

• 8/20 Sinks (Reg Ex.23)– 8 sinks vs. Plumbing Building System

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Capitalize

Cost to Improve Tangible Property

“Improvement” Examples in Regs• Entire Roof System (Reg Ex.14)

– Major Portion of Building Structural Component

• 200/300 Windows (Reg Ex.26)– Major Portion of Building Structural Component

• One Chiller in HVAC System (Reg Ex.17)– Major Component of HVAC Building System

• All Sinks (Reg Ex.22)– Major Portion of Plumbing Building System

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Capitalize

Cost to Improve Tangible Property

“Not a Restoration” 1 of 3 furnaces

30% of electrical wiring 10% of sq. ft. of flooring

“Restoration” Entire Sprinkler System

All Wiring in Building

40% of sq. ft. of flooring

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Capitalize

Cost to Improve Tangible Property

• Major Components – 40% or less “May Not” be a Restoration. (Ex.18,21,23,25)

– 66% or more “May” be a Restoration.

• Substantial Structural Parts – 25% Replacement “May Not” be a Restoration.(Ex. 30)

– 30% Replacement “May” be a Restoration. (Ex. 27) since it is a large portion of a structural part.

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Expense

Cost to Improve Tangible Property

Refresh

Capitalization is not needed.

• Does not materially increase capacity, productivity, efficiency, strength, quality or output of the building’s structure.

• A refresh keeps the building structure and building systems in ordinary efficient operating condition that is necessary to continue to attract customers.

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Cost to Improve Tangible PropertyUnit of Property - UOP

For Real and Personal Property (except buildings) • A Unit of Property is comprised of all components that are

functionally interdependent (i.e., the placing in service of one component is dependent on the placing in service of the other component).

For Buildings - Each Building is a UOP• Straight Line - Each Building is a UOP• Cost Segregation - Each Building’s 5,7,15 & 39 (27.5) yr. depreciable

lives property groups are UOPs

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Cost to Improve Tangible PropertyCapitalize or Expense?

Unit of Property – Buildings

Can I expense this invoice?

Betterment- Adaptation- Renovation?

What do I compare it to?

The Building?

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Cost to Improve Tangible Property

Improvement Standards – Buildings

Building Structural

Components

Building Systems

Compare Invoice to

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Cost to Improve Tangible Property

Improvement Standards – Buildings

Building Structural

Components*

• Roof• Windows• Exterior• Framing• Insulation• Doors• Foundation

Building & StructuralComponents,

HVAC Fire Protection Sys.Elevators/EscalatorsElectrical, Plumbing

Gas DistributionSecurity Sys.

Other

Building Systems

* - Discreet and Critical Function

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HVAC

CompressorBlowerInstruments

Ducts/Vents

Cost to Improve Tangible Property

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Cost to Improve Tangible Property

Compare future Invoices to:• Building Systems valuation• Structural Components valuation• Major Components valuation

Cost of Items

HVAC %

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Cost Segregation Expertise HD Study

Building Elements/Units of Property

Building Components $ 6.00

Cabinets / Millwork $ 20,085.41

Moldings $ 8,286.30

Wood Paneling $ 2,062.22

Flooring - Vinyl Tile $ 519.68

Flooring - Carpet $ 9,084.00

Window Treatments $ 187.90

Air Curtain $ 1,709.08

Building Signage $ 122.56

Specialty Electrical - Kitchen Equip. $ 15,216.78

Communication / Data $ 32,356.35

Specialty Plumbing - Cooler Equip. / Kitchen Sinks $ 10,181.63

Security / Exterior Lighting $ 9,827.88

FRP Wall Panels $ 1,003.24

Rear Entry Canopy $ 20,084.92

Interior Overhead Doors - Security $ 21,931.82

Slatwall / Pegboard Paneling $ 9,657.00

Surveillance System $ 4,375.25

Interior Wood Trellis Systems $ 6,046.21

Liner Panels $ 109,271.70

Paging System $ 1,688.23

Windmill $ 17,244.53

Exhaust Hood $ 11,258.61

Fire Extinguishers $ 1,833.25

Cooler $ 10,635.63

Movable Storage Units $ 30,431.69

Site Work / Improvements $ 5,464,546.00 Water Well $ 19,318.45

Site Drainage $ 48,990.57

Parking Lot $ 138,639.38

Exterior Signage Structure $ 17,790.84

Parking Lot Striping / Barriers $ 23,325.00

Sidewalks $ 711.12

Landscaping $ 68,635.17

Security Lighting Poles $ 6,374.77

Aggregate Base Paved Area $ 192,436.06

Exterior Fencing / Decking $ 31,986.93

Retaining Walls $ 16,024.07

Fabricated Steel - Bollards $ 2,926.12

Patio Concrete $ 10,848.65

Exterior Wood Trellis Systems $ 2,783.73

Gazebo $ 4,605.26

Building Structure $ 8.00 Structural Components $ 559,508.38 Roofing Systems $ 66,975.93 Foundations $ 234,535.89 HVAC $ 179,747.78 Electrical $ 242,472.40 Plumbing $ 68,844.81 Masonry $ 40,657.35 Doors & Windows $ 17,063.50 Insulation $ 43,168.87 Gas Distribution $ 4,989.84 Drywall $ 13,092.14 Painting $ 23,796.64 Fire Protection & Alarm $ 15,192.82 Gutters & Downspouts $ 12,335.58

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Cost to Improve Tangible Property

Buildings

Depreciation of UOP

Each Building is a Unit of Property

Or

Each Building’s Property by Class Life• 5 yr. Property• 7 yr. Property• 15 yr. Property• 39 (27.5) yr. Property

Improvement Standards

BAR Test

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Recommendations: Take Action List

• Late Partial Disposition study for 2014 tax year deadline.• Qualify Clients -Cost Segregation Preliminary Analysis. • Capitalization Policy in Place – AICPA Template.• De minimis Safe Harbor or Materials and Supplies.• Routine Maintenance Safe Harbor Form 3115.• Small Taxpayer Safe Harbor.

• Units of Properties Defined on Dep. Schedule• Track Expenses per Building and per Building Sys.

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Annual Elections

• De minimis Safe Harbor and Safe Harbor for Small TP on Buildings. (statement required)

• Capitalize Repairs and Maintenance Expenses. (statement required)

• Capitalize and Depreciate any rotable, temp, or emergency spare parts.

• Partial Disposition of a portion of a Building requires annual election in the year of disposition (starts in 2014). “Use It or Lose It”.

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Most Common3115s Change in Accounting Methods

• A change to apply late partial disposition on retired items.• A change to deducting as repairs and maintenance amounts

that were typically capitalized.• A change to deducting under the routine maintenance safe

harbor amounts that were typically capitalized.• A change to capitalizing and depreciating amounts typically

deducted as repairs and maintenance.• A change to deducting amounts paid for non-incidental

materials and supplies in the year they are used.• A change to deducting amounts paid for incidental materials

and supplies in the year paid or incurred.

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Journal of Accountancy Article

“Clearly, the new repair regulations pose considerable compliance risks both for CPAs and the businesses they advise.”

Journal of Accountancy Feb 2014Implementing the New Tangible Property Regulations Christian Wood. J.D.

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Solution:It’s the Process

• Find all clients with depreciation on building assets.

• Qualify clients with estimated Disposition and Cost Segregation economic needs.

• Get an Engineering-based Study that meets the IRS’s guideline.

• Apply the Change in Accounting Method Form 3115 & 481(a) with study results to the client’s return.

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Recommendations: Take Action List

• Late Partial Disposition study for 2014 tax year deadline.• Cost Segregation Preliminary Analysis. • Capitalization Policy in Place – AICPA Template.• De minimis Safe Harbor or Materials and Supply.• Routine Maintenance Safe Harbor Form 3115.• Units of Properties Defined on Dep. Schedule.• Track Expenses per Building and per Building Sys.

• Book Conformity.• Dear Client Letter – Start selling difficulty.• Resources to file CAM Form 3115 & 481(a)• Partner with Cost Segregation Firm (CSSI)

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CPA Implementation Process

PartneringQualification

& Analysis

Client Contact

& Proposal

Execution

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Use the CSSI ExperienceTax Savings. Delivered.

Performing Engineering-based Studies for over 13 years, National capability, 9,500 Studies completed across the U.S., always on-time.

Qualify the tax savings estimates within 48 hrs. for your client.

Full Engineering-based Studies completed in 4-8 weeks.

Perform Change in Accounting Method Form 3115 and 481(a) adjustments.

Use CSSI as your engineering-based service provider for your clients.

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TPR Implementation Cycle

CSSIResource

Guide Friend Trusted Advisor

Cost Segregation Professional

Advisor

Preliminary Analysis

Recommend Process

Implementation

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Request These Resource Docs

CCH - Executive SummariesAICPA 6 Page Bullet Summary

Index of Examples in Fed RegisterQuestions and Answers

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Thank YouLooking forward to your call

Get Your Cheese Back America

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Thank YouLooking forward to your call

Thank You

Your NameCost Segregation Services, Inc. (CSSI)

Phone NumberE-mail

David [email protected]

www.CostSegregationServices.com

Friends Don’t Let Friends …Overpay their Taxes