Rev. Proc. 2016-23 - Rev. Proc. 2016–23

Rev. Proc. 2016-23
in: Rev. Proc. 2016-23 - Rev. Proc. 2016–23

Rev. Proc. 2016–23

SECTION 1. PURPOSE

This revenue procedure provides: (1) limitations on depreciation deductions for owners of passenger automobiles first placed in service by the taxpayer during calendar year 2016, including separate tables of limitations on depreciation deductions for trucks and vans; (2) amounts that must be included in income by lessees of passenger automobiles first leased by the taxpayer during calendar year 2016, including a separate table of inclusion amounts for lessees of trucks and vans; and (3) revised tables of depreciation limitations and lessee inclusion amounts for passenger automobiles that were first placed in service or first leased by the taxpayer, respectively, during 2015 and to which the 50-percent additional first year depreciation deduction under § 168(k)(1)(A) of the Internal Revenue Code applies as extended by § 143(a) of the Protecting Americans from Tax Hikes Act of 2015 (the Act), enacted as part of the Consolidated Appropriations Act, 2016, Division Q, Pub. L. No. 114–113, 129 Stat. 2242 (December 18, 2015). The tables detailing these depreciation limitations and lessee inclusion amounts reflect the automobile price inflation adjustments required by § 280F(d)(7).

SECTION 2. BACKGROUND

.01 For owners of passenger automobiles, § 280F(a) imposes dollar limitations on the depreciation deduction for the year the taxpayer places the passenger automobile in service and for each succeeding year. For passenger automobiles placed in service after 1988, § 280F(d)(7) requires the Internal Revenue Service to increase the amounts allowable as depreciation deductions by a price inflation adjustment amount. The method of calculating this price inflation amount for trucks and vans placed in service in or after calendar year 2003 uses a different CPI “automobile component” (the “new trucks” component) than that used in the price inflation amount calculation for other passenger automobiles (the “new cars” component), resulting in somewhat higher depreciation deductions for trucks and vans. This change reflects the higher rate of price inflation for trucks and vans since 1988.

.02 Section 168(k)(1) provides that, in the case of qualified property, the depreciation deduction allowed under § 167(a) for the taxable year in which the property is placed in service includes an allowance equal to 50 percent of the property’s adjusted basis (hereinafter, referred to as “§ 168(k) additional first year depreciation deduction”). Prior to the Act, § 168(k)(1) did not apply to property generally placed in service after December 31, 2014. Section 143(b) of the Act extended the § 168(k) additional first year depreciation deduction to qualified property (as defined in § 168(k)(2) after the amendments made by § 143(b)(1) of the Act) placed in service by the taxpayer after December 31, 2015, and generally before January 1, 2020. The § 168(k) additional first year depreciation deduction percentage is 50 percent for qualified property placed in service during calendar year 2016. Section 168(k)(2)(F)(i) and (iii), as amended by § 143(b)(1) of the Act, increase the first year depreciation allowed under § 280F(a)(1)(A)(i) by $8,000 for passenger automobiles placed in service by the taxpayer before January 1, 2018, and to which the § 168(k) additional first year depreciation deduction applies.

.03 Tables 1 through 4 of this revenue procedure provide depreciation limitations for passenger automobiles placed in service during calendar year 2016. Table 1 (passenger automobiles that are not trucks or vans) and Table 2 (trucks and vans) provide depreciation limitations for passenger automobiles for which the § 168(k) additional first year depreciation deduction, as amended by § 143(b) of the Act, applies. Table 3 (passenger automobiles that are not trucks or vans) and Table 4 (trucks and vans) provide depreciation limitations for passenger automobiles for which the § 168(k) additional first year depreciation deduction, as amended by § 143(b) of the Act, does not apply. The § 168(k) additional first year depreciation deduction, as amended by § 143(b) of the Act, does not apply for 2016 if the taxpayer: (1) acquired the passenger automobile used; (2) did not use the passenger automobile during 2016 more than 50 percent for business purposes; (3) elected out of the § 168(k) additional first year depreciation deduction pursuant to § 168(k)(7), as added by § 143(b)(6)(D) of the Act; or (4) elected to increase the alternative minimum tax (AMT) credit limitation under § 53, instead of claiming the § 168(k) additional first year depreciation deduction, for qualified property placed in service during 2016 pursuant to § 168(k)(4), as amended by § 143(b)(3) of the Act.

.04 Section 280F(c) requires a reduction in the deduction allowed to the lessee of a leased passenger automobile. The reduction must be substantially equivalent to the limitations on the depreciation deductions imposed on owners of passenger automobiles. Under § 1.280F–7(a) of the Income Tax Regulations, this reduction requires a lessee to include in gross income an amount determined by applying a formula to the amount obtained from a table. Table 5 applies to lessees of passenger automobiles that are not trucks and vans and Table 6 applies to lessees of trucks and vans. Each table shows inclusion amounts for a range of fair market values for each taxable year after the passenger automobile is first leased.

.05 Section 143(a) of the Act extended the 50-percent additional first year depreciation deduction under § 168(k) to qualified property (as defined in § 168(k)(2)) acquired by the taxpayer after December 31, 2007, and before January 1, 2016, if no written binding contract for the acquisition of the property existed before January 1, 2008, and if the taxpayer places the property in service generally before January 1, 2016. Section 168(k)(2)(F)(i) increases the first year depreciation allowed under § 280F(a)(1)(A)(i) by $8,000 for passenger automobiles to which the § 168(k) additional first year depreciation deduction applies. Accordingly, Tables 7 and 8 of this revenue procedure update Rev. Proc. 2015–19, 2015–8 I.R.B. 656, by providing revised depreciation limitations for passenger automobiles placed in service during calendar year 2015 for which the § 168(k) additional first year depreciation deduction, as extended by § 143(a) of the Act, applies. This revenue procedure also updates the lease inclusion amounts in Tables 3 and 4 of Rev. Proc. 2015–19 for passenger automobiles first leased by the taxpayer in calendar year 2015.

SECTION 3. SCOPE

.01 The limitations on depreciation deductions in section 4.01(2) of this revenue procedure apply to passenger automobiles (other than leased passenger automobiles) that are placed in service by the taxpayer in calendar year 2016, and continue to apply for each taxable year that the passenger automobile remains in service.

.02 The tables in section 4.02 of this revenue procedure apply to leased passenger automobiles for which the lease term begins during calendar year 2016. Lessees of these passenger automobiles must use these tables to determine the inclusion amount for each taxable year during which the passenger automobile is leased. See Rev. Proc. 2011–21, 2011–12 I.R.B. 560, for passenger automobiles first leased during calendar year 2011; Rev. Proc. 2012–23, 2012–14 I.R.B. 712, for passenger automobiles first leased during calendar year 2012; Rev. Proc. 2013–21, 2013–12 I.R.B. 660, for passenger automobiles first leased during calendar year 2013; Rev. Proc. 2014–21, 2014–11 I.R.B. 641, as amplified and modified by section 4.03 of Rev. Proc. 2015–19, 2015–8 I.R.B. 656, for passenger automobiles first leased during calendar year 2014; and Rev. Proc. 2015–19, as amplified and modified by section 4.03 of this revenue procedure, for passenger automobiles first leased during calendar year 2015.

SECTION 4. APPLICATION

.01 Limitations on Depreciation Deductions for Certain Automobiles.

(1) Amount of the inflation adjustment.

(a) Passenger automobiles (other than trucks or vans). Under § 280F(d)(7)(B)(i), the automobile price inflation adjustment for any calendar year is the percentage (if any) by which the CPI automobile component for October of the preceding calendar year exceeds the CPI automobile component for October 1987. Section 280F(d)(7)(B)(ii) defines the term “CPI automobile component” as the automobile component of the Consumer Price Index for all Urban Consumers published by the Department of Labor. The new car component of the CPI was 115.2 for October 1987 and 143.516 for October 2015. The October 2015 index exceeded the October 1987 index by 28.316. Therefore, the automobile price inflation adjustment for 2016 for passenger automobiles (other than trucks and vans) is 24.6 percent (28.316/115.2 x 100%). The dollar limitations in § 280F(a) are multiplied by a factor of 0.246, and the resulting increases, after rounding to the nearest $100, are added to the 1988 limitations to give the depreciation limitations applicable to passenger automobiles (other than trucks and vans) for calendar year 2016. This adjustment applies to all passenger automobiles (other than trucks and vans) that are first placed in service in calendar year 2016.

(b) Trucks and vans. To determine the dollar limitations for trucks and vans first placed in service during calendar year 2016, the Service uses the new truck component of the CPI instead of the new car component. The new truck component of the CPI was 112.4 for October 1987 and 155.035 for October 2015. The October 2015 index exceeded the October 1987 index by 42.635. Therefore, the automobile price inflation adjustment for 2016 for trucks and vans is 37.9 percent (42.635/112.4 x 100%). The dollar limitations in § 280F(a) are multiplied by a factor of 0.379, and the resulting increases, after rounding to the nearest $100, are added to the 1988 limitations to give the depreciation limitations for trucks and vans. This adjustment applies to all trucks and vans that are first placed in service in calendar year 2016.

(2) Amount of the limitation. Tables 1 through 4 contain the dollar amount of the depreciation limitation for each taxable year for passenger automobiles a taxpayer places in service in calendar year 2016. Use Table 1 for a passenger automobile (other than a truck or van), and Table 2 for a truck or van, placed in service in calendar year 2016 for which the § 168(k) additional first year depreciation deduction applies. Use Table 3 for a passenger automobile (other than a truck or van), and Table 4 for a truck or van, placed in service in calendar year 2016 for which the § 168(k) additional first year depreciation deduction does not apply.

REV. PROC. 2016–23 TABLE 1
DEPRECIATION LIMITATIONS FOR PASSENGER AUTOMOBILES (THAT ARE NOT TRUCKS OR VANS) PLACED IN SERVICE IN CALENDAR YEAR 2016 FOR WHICH THE § 168(k) ADDITIONAL FIRST YEAR DEPRECIATION DEDUCTION APPLIES
------
Tax YearAmount
1st Tax Year$ 11,160
2nd Tax Year$ 5,100
3rd Tax Year$ 3,050
Each Succeeding Year$ 1,875
REV. PROC. 2016–23 TABLE 2
DEPRECIATION LIMITATIONS FOR TRUCKS AND VANS PLACED IN SERVICE IN CALENDAR YEAR 2016 FOR WHICH THE § 168(k) ADDITIONAL FIRST YEAR DEPRECIATION DEDUCTION APPLIES
------
Tax YearAmount
1st Tax Year$ 11,560
2nd Tax Year$ 5,700
3rd Tax Year$ 3,350
Each Succeeding Year$ 2,075
REV. PROC. 2016–23 TABLE 3
DEPRECIATION LIMITATIONS FOR PASSENGER AUTOMOBILES (THAT ARE NOT TRUCKS OR VANS) PLACED IN SERVICE IN CALENDAR YEAR 2016 FOR WHICH THE § 168(k) ADDITIONAL FIRST YEAR DEPRECIATION DEDUCTION DOES NOT APPLY
------
Tax YearAmount
1st Tax Year$ 3,160
2nd Tax Year$ 5,100
3rd Tax Year$ 3,050
Each Succeeding Year$ 1,875
REV. PROC. 2016–23 TABLE 4
DEPRECIATION LIMITATIONS FOR TRUCKS AND VANS PLACED IN SERVICE IN CALENDAR YEAR 2016 FOR WHICH THE § 168(k) ADDITIONAL FIRST YEAR DEPRECIATION DEDUCTION DOES NOT APPLY
------
Tax YearAmount
1st Tax Year$ 3,560
2nd Tax Year$ 5,700
3rd Tax Year$ 3,350
Each Succeeding Year$ 2,075

.02 Inclusions in Income of Lessees of Passenger Automobiles.

A taxpayer must follow the procedures in § 1.280F–7(a) for determining the inclusion amounts for passenger automobiles first leased in calendar year 2016. In applying these procedures, lessees of passenger automobiles other than trucks and vans should use Table 5 of this revenue procedure, while lessees of trucks and vans should use Table 6 of this revenue procedure.

REV. PROC. 2016–23 TABLE 5
DOLLAR AMOUNTS FOR PASSENGER AUTOMOBILES (THAT ARE NOT TRUCKS OR VANS) WITH A LEASE TERM BEGINNING IN CALENDAR YEAR 2016
---------------------
Fair Market Value of Passenger AutomobileTax Year During Lease
---------------------
OverNot Over1st2nd3rd4th5th & later
---------------------
$19,000$19,500613202327
19,50020,000715232730
20,00020,500817263035
20,50021,000919293339
21,00021,5001021313842
21,50022,0001123344147
22,00023,0001226394653
23,00024,0001430445460
24,00025,0001634506069
25,00026,0001738566778
26,00027,0001942627485
27,00028,0002146688193
28,00029,00023507389101
29,00030,00025538095110
30,00031,000265885102118
31,00032,000286291109126
32,00033,000306598116134
33,00034,0003269103123142
34,00035,0003473109130150
35,00036,0003577115137158
36,00037,0003781121144166
37,00038,0003985127151174
38,00039,0004189132158183
39,00040,0004293138166190
40,00041,0004497144172199
41,00042,00046101150179207
42,00043,00048105155187215
43,00044,00050109161193223
44,00045,00051113167201231
45,00046,00053117173207239
46,00047,00055121179214247
47,00048,00057124185222255
48,00049,00059128191228264
49,00050,00060133196236271
50,00051,00062136203242280
51,00052,00064140209249288
52,00053,00066144214257295
53,00054,00068148220263304
54,00055,00069152226271312
55,00056,00071156232277320
56,00057,00073160238284328
57,00058,00075164243292336
58,00059,00077168249298345
59,00060,00078172255306352
60,00062,00081178264316364
62,00064,00085185276330381
64,00066,00088194287344397
66,00068,00092201299358413
68,00070,00095209311372430
70,00072,00099217322387445
72,00074,000102225334400462
74,00076,000106233346414478
76,00078,000110241357428494
78,00080,000113249369442510
80,00085,000120262390467538
85,00090,000128282419502579
90,00095,000137302448537620
95,000100,000146322477572660
100,000110,000160351521625721
110,000120,000178390580695801
120,000130,000196430638765882
130,000140,000214469697835963
140,000150,0002325087559061,044
150,000160,0002495488149751,126
160,000170,0002675888721,0451,207
170,000180,0002856279301,1161,288
180,000190,0003036669891,1861,368
190,000200,0003217061,0471,2561,449
200,000210,0003397451,1061,3261,530
210,000220,0003577841,1651,3961,611
220,000230,0003758241,2231,4661,692
230,000240,0003938631,2811,5371,773
240,000and over4119021,3401,6071,854
REV. PROC. 2016–23 TABLE 6
DOLLAR AMOUNTS FOR TRUCKS AND VANS WITH A LEASE TERM BEGINNING IN CALENDAR YEAR 2016
---------------------
Fair Market Value of Truck or VanTax Year During Lease
---------------------
OverNot Over1st2nd3rd4th5th & later
---------------------
$19,500$20,00038121416
20,00020,500410151720
20,50021,000512172125
21,00021,500614202528
21,50022,000716232832
22,00023,000819283338
23,00024,0001023334146
24,00025,0001226404755
25,00026,0001430465463
26,00027,0001634516270
27,00028,0001738586879
28,00029,0001942637686
29,00030,0002146698295
30,00031,00023507589103
31,00032,00025548097111
32,00033,000265886104119
33,00034,000286292111127
34,00035,000306698117136
35,00036,0003270104124143
36,00037,0003473110132151
37,00038,0003578115139160
38,00039,0003782121146167
39,00040,0003985128152176
40,00041,0004189133160184
41,00042,0004294139166192
42,00043,0004497145174200
43,00044,00046101151181208
44,00045,00048105157187217
45,00046,00050109162195224
46,00047,00051113169201233
47,00048,00053117174209240
48,00049,00055121180216248
49,00050,00057125186222257
50,00051,00059129191230265
51,00052,00060133197237273
52,00053,00062137203244281
53,00054,00064141209250290
54,00055,00066144216257298
55,00056,00068148221265305
56,00057,00069153226272314
57,00058,00071156233279321
58,00059,00073160239285330
59,00060,00075164244293338
60,00062,00077170253304350
62,00064,00081178265317366
64,00066,00085186276331383
66,00068,00088194288345399
68,00070,00092202299360414
70,00072,00095210311374431
72,00074,00099217324387447
74,00076,000102226335401463
76,00078,000106233347415480
78,00080,000110241358430495
80,00085,000116255379454524
85,00090,000125274409489564
90,00095,000134294437525605
95,000100,000143314466560645
100,000110,000156344510612706
110,000120,000174383569682787
120,000130,000192422628752868
130,000140,000210462685823949
140,000150,0002285017448931,030
150,000160,0002465408039631,111
160,000170,0002645808611,0331,192
170,000180,0002826199201,1021,274
180,000190,0003006589791,1721,354
190,000200,0003186981,0361,2431,435
200,000210,0003357381,0951,3131,516
210,000220,0003537771,1541,3831,597
220,000230,0003718161,2121,4541,678
230,000240,0003898561,2701,5241,759
240,000and over4078951,3291,5941,839

.03 Revised Amounts for Passenger Automobiles Placed in Service During 2015.

(1) Calculation of the Revised Amount. The revised depreciation limits provided in this section 4.03 were calculated by increasing the existing limitations on the first year allowance in Rev. Proc. 2015–19 by $8,000 as provided in § 168(k)(2)(F)(i).

(2) Amount of the Revised Limitation. For passenger automobiles (that are not trucks or vans) placed in service by the taxpayer in calendar year 2015 for which the § 168(k) additional first year depreciation deduction applies, Table 7 of this revenue procedure contains the revised dollar amount of the depreciation limitations for each taxable year. For trucks or vans placed in service by the taxpayer in calendar year 2015 for which the § 168(k) additional first year depreciation deduction applies, Table 8 of this revenue procedure contains the revised dollar amount of the depreciation limitations for each taxable year. If the § 168(k) additional first year depreciation deduction does not apply to a passenger automobile placed in service by the taxpayer in calendar year 2015, the depreciation limitations for each taxable year in Tables 1 and 2 of Rev. Proc. 2015–19 apply.

REV. PROC. 2016–23 TABLE 7
DEPRECIATION LIMITATIONS FOR PASSENGER AUTOMOBILES (THAT ARE NOT TRUCKS OR VANS) PLACED IN SERVICE IN CALENDAR YEAR 2015 FOR WHICH THE § 168(k) ADDITIONAL FIRST YEAR DEPRECIATION DEDUCTION APPLIES
------
Tax YearAmount
1st Tax Year$ 11,160
2nd Tax Year$ 5,100
3rd Tax Year$ 3,050
Each Succeeding Year$ 1,875
REV. PROC. 2016–23 TABLE 8
DEPRECIATION LIMITATIONS FOR TRUCKS AND VANS PLACED IN SERVICE IN CALENDAR YEAR 2015 FOR WHICH THE § 168(k) ADDITIONAL FIRST YEAR DEPRECIATION DEDUCTION APPLIES
------
Tax YearAmount
1st Tax Year$11,460
2nd Tax Year$ 5,600
3rd Tax Year$ 3,350
Each Succeeding Year$ 1,975

(3) Modification to lease inclusion amounts for 2015. The lease inclusion amounts in Tables 3 and 4 of Rev. Proc. 2015–19 are modified by striking the first three lines of inclusion amounts in Table 3 and the first two lines of inclusion amounts in Table 4. Consequently, Table 3 of Rev. Proc. 2015–19 applies to passenger automobiles (other than trucks and vans) that are first leased by the taxpayer in calendar year 2015 with a fair market value over $19,000, and Table 4 of Rev. Proc. 2015–19 applies to trucks and vans that are first leased by the taxpayer in calendar year 2015 with a fair market value over $19,500.

SECTION 5. EFFECTIVE DATE

This revenue procedure, with the exception of section 4.03, applies to passenger automobiles that a taxpayer first places in service or first leases during calendar year 2016. Section 4.03 of this revenue procedure applies to passenger automobiles that a taxpayer first places in service or first leases during calendar year 2015.

SECTION 6. EFFECT ON OTHER DOCUMENTS

Rev. Proc. 2015–19 is amplified and modified.

SECTION 7. DRAFTING INFORMATION

The principal author of this revenue procedure is Bernard P. Harvey of the Office of Associate Chief Counsel (Income Tax & Accounting). For further information regarding this revenue procedure, contact Mr. Harvey at (202) 317-7005 (not a toll-free number).

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