Under the current depreciation system (generally applicable to tangible property placed in service after 1986), depreciation is calculated using an applicable method, period, and convention. To compute the deduction for the year the property is placed in service and the year the property is disposed of or retired, the tax code uses averaging conventions to establish deemed placed-in-service and retirement dates. Depreciation is allowed for the portion of the tax year that the property is placed in service under the applicable convention.
Under the tax code, the applicable convention generally is the half-year convention, although other conventions (mid-month or mid-quarter) may also apply. The half-year convention applies to all depreciable property other than residential rental property and nonresidential real property, unless the mid-quarter convention applies. (The mid-month convention applies to residential rental property, nonresidential real property, and certain railroad property.) The mid-quarter convention is used in place of the half-year convention if more than 40 percent of the cost of property (other than real property) is placed in service in the last quarter of the tax year.
The convention applies to the first year and the last year of depreciation. Property that is placed in service after the beginning of the tax year is entitled to six months of depreciation. The property is also entitled to six months of depreciation in the year of disposal or in the year that the useful life expires (as if the property were sold at the mid-point of the tax year). The averaging convention must be followed consistently for an asset account.
Depreciation under the half-year convention is calculated by treating all property as if it were placed in service on the first day of the second half of the tax year (July 1 for a calendar year taxpayer), the midpoint of the tax year. Similarly, property that is retired during the year is treated as retired on the first day of the second half of the tax year. The amount of depreciation in a tax year when the half-year convention applies is one-half the amount that would be allowed by taking depreciation for the full tax year.
Example. A calendar year taxpayer purchases a machine on January 1 and begins to use it on February 1, The applicable convention determines the placed-in-service date and the calculation of depreciation. Under the half-year convention, the machine is deemed to be placed in service on July 1, even though it was actually placed in service on February 1. The taxpayer can take six months of depreciation for the period July 1 to December 31 of the first year. If property previously placed in service were retired on February 1 (and the property had not been fully depreciated), the property would be treated as disposed of on June 30, and the taxpayer could take six months of depreciation.
Contact Doeren Mayhew for more information.
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