50% special depreciation allowance for foreign asset

[jmc]

Section 179 deduction is not allowed for assets used in foreign country.
But, I could not find specific ruling for 50% special depreciation allowance for assets used in foreign country.

[Bees Knees]

The special depreciation allowance is described in Code Section 168(k). Qualified property is listed in Code Section 168(k)(2). Code Section 168(k)(2)(D) lists exceptions to qualified property. Code Section 168(k)(2)(D)(i) says:

The term “qualified property” shall not include any property to which the alternative depreciation system under subsection (g) applies…

Code Section 168(g) says:

(g) Alternative depreciation system for certain property

(1) In general
In the case of—

(A) any tangible property which during the taxable year is used predominantly outside the United States,

(B) any tax-exempt use property,

(C) any tax-exempt bond financed property,

(D) any imported property covered by an Executive order under paragraph (6), and

(E) any property to which an election under paragraph (7) applies,

the depreciation deduction provided by section 167 (a) shall be determined under the alternative depreciation system.

Thus, since property used outside the U.S. must be depreciated under ADS rather than GDS, the Special Depreciation Allowance cannot be taken.