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History of Cost Segregation

Cost Segregation has a rich history dating back to the latter half of the 20th century. This innovative financial practice has evolved in response to changing tax laws, IRS guidelines, and the need for businesses and investors to optimize their tax benefits. Its path reflects the constant adaptability of tax professionals and their commitment to maximizing financial efficiency within a dynamic economic landscape. Over the years, cost segregation has become an indispensable tool for individuals and enterprises looking to enhance cash flow, reduce tax liability, and make the most of their real estate investments.

Here is a brief overview of the history of cost segregation:

Early Development (1960s - 1970s)

Cost segregation emerged in the 1960s when taxpayers began challenging the IRS's approach to depreciating real property. During this time, taxpayers argued that specific components of commercial buildings had shorter valuable lives than the standard 39-year or 27.5-year depreciation schedules set by the IRS. Legal cases during this period laid the groundwork for the future development of cost segregation.


Growth of the Strategy: In the 1980s, the tax landscape continued to evolve, and cost segregation gained more attention. Taxpayers and tax professionals began to explore the strategy to accelerate depreciation deductions for specific building components. The IRS started issuing rulings and guidance on cost segregation, which helped clarify the rules and requirements.

Tax Reform Act of 1986

The Tax Reform Act of 1986 made significant changes to the tax code, including changes to depreciation rules. This led to further interest in cost segregation as property owners sought ways to optimize their tax deductions within the new tax framework. This legislation introduced the Modified Accelerated Cost Recovery System (MACRS) for tax depreciation. Under MACRS, certain assets could be depreciated mor rapidly than the building itself.

Increased Popularity

With more precise guidelines and a better understanding of the benefits, cost segregation became a mainstream tax strategy for commercial property owners and investors. The practice gained traction, particularly among real estate developers, owners of large commercial properties, and businesses looking to optimize their tax liabilities.

Continued Legal Challenges

Over the years, there have been legal challenges and disputes between taxpayers and the IRS over the classification and depreciation of specific building components. These disputes have further shaped the rules and practices surrounding cost segregation.

Ongoing Evolution

Cost segregation is a practice that remains ever-changing, adapting in response to evolving tax laws and regulations. As tax legislation is subject to periodic updates, the strategies employed in cost segregation continually evolve to align with the latest rules and guidelines. This dynamic nature of cost segregation underscores the need for businesses and tax professionals to stay informed and agile, ensuring that they can effectively maximize tax benefits while complying with the current regulatory landscape.

IRS Guidelines and Rulings (1990s - 2000s):

The 1990s and early 2000s saw the IRS issue guidelines and rulings that provided more clarity on cost segregation. Revenue Procedure 96-31 in 1996 and Revenue Procedure 2002-19 in 2002 established rules and safe harbors for cost segregation studies, making it easier for taxpayers to apply the strategy while staying compliant with IRS regulations.

It’s important to note that tax laws and regulations can change, and the popularity and practice of cost segregation may continue to evolve. Property owners and investors interested in cost segregation should consult with tax professionals or cost segregation experts to ensure they comply with the latest tax codes and guidelines.

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Case Study

Residential Rental in St. George, Utah
First Year Increased Depreciation: $1.6M

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