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AMT adjustment for SL

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    AMT adjustment for SL

    Conservative Mortimer starts a business in 2012 that he is certain will take a 3-4 years to be profitable, and requires a large amount of capital equipment in the first year. For long-term strategy he wants to save as much depreciation for profitable years. He is thus not interested in s.179, bonus, or declining-balance depreciation, and elects 10 years and straight-line depreciation for otherwise 7-year property under alternate MACRS class 24.4.

    Making a long story short, he has 7-year property, but is electing 10 yr. straight-line.

    The AMT depreciation calculation for this property should be:

    1) 7-yr. 150% the listed AMT allowance for the property.
    2) 7-yr. 100% because he is not electing declining-balance, even though AMT would allow it.
    3) 10-yr. 150% because he is not electing 7 years, even though AMT would allow it.
    4) 10-yr. 100% because AMT seeks no adjustment unless taxpayer elects more aggressive than 7yr 150%.

    #2
    I vote for #4.

    Form 4626 instructions: "What Depreciation Is Not Refigured for the AMT? ... Property for which the corporation elected to use the alternative depreciation system (ADS) for the regular tax."

    IRC 56(a)(1) is a bunch of gibberish, but I think it confirms that it is 100%.

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