A discussion on the other board over straight-line depreciation for cars prompted me to post this:
Rev. Proc. 2004-64 says:
“The business standard mileage rate may not be used to compute the deductible expenses of an automobile for which the taxpayer has (a) claimed depreciation using a method other than straight-line for its estimated useful life, (b) claimed a section 179 deduction, or (c) used the Accelerated Cost Recovery System under former section 168 or the Modified Accelerated Cost Recovery System (MACRS) under current section 168. By using the business standard mileage rate, the taxpayer has elected to exclude the automobile (if owned) from MACRS pursuant to section 168(f)(1). If, after using the business standard mileage rate, the taxpayer uses actual costs, the taxpayer must use straight-line depreciation for the automobile's remaining estimated useful life (subject to the applicable depreciation deduction limitations under section 280F).”
The confusion here lies in what is meant by straight-line depreciation for the remaining estimated useful life.
This is referring to straight-line depreciation that pre-dates ACRS and MACRS depreciation where you have a prescribed class life for various kinds of assets as opposed to having to “estimate” the useful life of an asset.
Prior to 1981, you would guess, or estimate what you thought the life of an asset would be, subtract out the estimated salvage value of it at the end of that life, and then depreciate it straight-line, allocating the first and last year depreciation by the number of months it was in service for those years.
Straight-line election under MACRS does not do it this way. MACRS has you use the prescribed class life for that asset (cars would be 5 years), and use either the half-year or mid-quarter conventions for the first and last year.
The question then that comes up: “Can I use actual expenses and straight-line over its estimated useful life in year one so that I can switch back and forth from year to year between the actual expense method and the standard mileage method?” Maybe I have one year where there are high repair costs, so actual expenses would be more advantages, but then another year where high mileage and low maintenance makes the standard mileage method better.
Well, what does the Rev. Proc. above say? Can you elect straight-line over estimated useful life in year one? The Rev. Proc. does not say you can. I am not aware of any election to use straight-line other than Section 168(b)(3)(D) and Section 168(g)(1)(E), both of which allows you to elect straight-line without regard to salvage value using a prescribed asset class life. In other words, these are still MACRS cost recovery methods under Section 168 that disqualify you from switching to the standard mileage method under Rev. Proc. 2004-64.
That being said, then, if you use actual expenses in year one, even if straight line depreciation is elected, you have disqualified that car from ever switching to the standard mileage method. It is stuck using actual expenses for all eternity.
How about this question: If I use the standard mileage method in year one, can I ever switch to actual expenses?
The Rev. Proc. says yes. It says:
“If, after using the business standard mileage rate, the taxpayer uses actual costs, the taxpayer must use straight-line depreciation for the automobile's remaining estimated useful life (subject to the applicable depreciation deduction limitations under section 280F).”
I think that is pretty clear. It appears to be a special case where a taxpayer can use pre-1981 straight line depreciation after a year in which the standard mileage method was used.
So bottom line is you have two choices in year one:
1) If you use actual expenses in year one, you can never switch to the standard mileage method in any following year for that car.
2) If you use standard mileage method in year one, you can switch to actual expenses in a following year, but you must use straight-line over its remaining estimated useful life with salvage value and all the other pre-1981 rules, subject to Section 280F limits.
Rev. Proc. 2004-64 says:
“The business standard mileage rate may not be used to compute the deductible expenses of an automobile for which the taxpayer has (a) claimed depreciation using a method other than straight-line for its estimated useful life, (b) claimed a section 179 deduction, or (c) used the Accelerated Cost Recovery System under former section 168 or the Modified Accelerated Cost Recovery System (MACRS) under current section 168. By using the business standard mileage rate, the taxpayer has elected to exclude the automobile (if owned) from MACRS pursuant to section 168(f)(1). If, after using the business standard mileage rate, the taxpayer uses actual costs, the taxpayer must use straight-line depreciation for the automobile's remaining estimated useful life (subject to the applicable depreciation deduction limitations under section 280F).”
The confusion here lies in what is meant by straight-line depreciation for the remaining estimated useful life.
This is referring to straight-line depreciation that pre-dates ACRS and MACRS depreciation where you have a prescribed class life for various kinds of assets as opposed to having to “estimate” the useful life of an asset.
Prior to 1981, you would guess, or estimate what you thought the life of an asset would be, subtract out the estimated salvage value of it at the end of that life, and then depreciate it straight-line, allocating the first and last year depreciation by the number of months it was in service for those years.
Straight-line election under MACRS does not do it this way. MACRS has you use the prescribed class life for that asset (cars would be 5 years), and use either the half-year or mid-quarter conventions for the first and last year.
The question then that comes up: “Can I use actual expenses and straight-line over its estimated useful life in year one so that I can switch back and forth from year to year between the actual expense method and the standard mileage method?” Maybe I have one year where there are high repair costs, so actual expenses would be more advantages, but then another year where high mileage and low maintenance makes the standard mileage method better.
Well, what does the Rev. Proc. above say? Can you elect straight-line over estimated useful life in year one? The Rev. Proc. does not say you can. I am not aware of any election to use straight-line other than Section 168(b)(3)(D) and Section 168(g)(1)(E), both of which allows you to elect straight-line without regard to salvage value using a prescribed asset class life. In other words, these are still MACRS cost recovery methods under Section 168 that disqualify you from switching to the standard mileage method under Rev. Proc. 2004-64.
That being said, then, if you use actual expenses in year one, even if straight line depreciation is elected, you have disqualified that car from ever switching to the standard mileage method. It is stuck using actual expenses for all eternity.
How about this question: If I use the standard mileage method in year one, can I ever switch to actual expenses?
The Rev. Proc. says yes. It says:
“If, after using the business standard mileage rate, the taxpayer uses actual costs, the taxpayer must use straight-line depreciation for the automobile's remaining estimated useful life (subject to the applicable depreciation deduction limitations under section 280F).”
I think that is pretty clear. It appears to be a special case where a taxpayer can use pre-1981 straight line depreciation after a year in which the standard mileage method was used.
So bottom line is you have two choices in year one:
1) If you use actual expenses in year one, you can never switch to the standard mileage method in any following year for that car.
2) If you use standard mileage method in year one, you can switch to actual expenses in a following year, but you must use straight-line over its remaining estimated useful life with salvage value and all the other pre-1981 rules, subject to Section 280F limits.
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