9100 3.
Partial disposition of roof.
Alice has owned an apartment building for ten years.
The partial asset disposition election may provide taxpayers with significant tax deductions.
The final regulations also retain the partial disposition rule in the 2013 proposed regulations.
Two important matters that practitioners should continue to monitor are partial asset dispositions and de minimis safe harbor elections.
Consequently the disposition rules in the final regulations apply to a partial disposition of an asset for example the disposition of a roof or a portion of a roof.
When the disrepair of a roof becomes significant enough to impede the normal functions of the building structure the cost of the work must be capitalized as a restoration.
Unlike the partial disposition loss taken via the election the optional deduction of removal costs is considered a tax accounting method.
Taxpayers who previously have adopted this method will capture the deductions on the amended return filed to make the late partial disposition election under regs.
To get a 1231 loss to flow thru to the tax return requires us to claim a total disposition of the retired asset.
If so the cost of the roof work is capitalized as a restoration.
Was the roof work performed because of some other capital improvement project.
For example a loss could not be recognized when an old roof was disposed and replaced with a new roof.
If we do a partial disposition of say a retired roof the loss upon the sale of the retired roof would be suspended until such time that there is total disposition of the original asset.
Did the taxpayer claim a retirement loss or partial disposition deduction for any portion of the old roof.
Alice may not recognize a loss and must continue to depreciate the retired old roof unless she elects to treat the roof retirement as a partial disposition of the building.
9100 2 or 301.
Did the taxpayer claim a retirement loss or partial disposition deduction for any portion of the old roof.
She replaces the roof which is a structural component.
Part of a larger improvement.
By providing basic data the calculator provides a ppi adjusted value while considering the condition of the respective component at the time it was acquired accomplished by considering the component s normal life.
The kbkg partial disposition calculator is designed to make calculations as simple as possible while minimizing unnecessary work.
If yes the cost of the work is capitalized as a restoration.
Additional questions to ask to assess proper tax treatment.