Turning IRS Rules Into Growth Capital™ for Commercial Real Estate

The One Big Beautiful Bill Act (OBBBA), signed in July 2025, permanently reinstated 100% bonus depreciation for qualified property placed in service on or after January 19, 2025. Combined with Cost Segregation, §179D Energy Deductions, and Reusable Wall Systems (GreenZip™), this update delivers stronger after-tax ROI for developers, brokers, and investors.

2025 Update — Permanent 100% Bonus Depreciation (OBBBA)

  • Applies to eligible property placed in service on or after January 19, 2025.

  • Assets placed in service before that date follow prior phase-down rules (e.g., 40 %).

  • Eliminates all step-downs — the 80 % phase-out is now obsolete.

  • Acquisition timing matters: only assets acquired and placed in service after Jan 19 qualify.

  • Qualified property rules under §168(k) remain unchanged (5-, 7-, and 15-year via Cost Segregation

Example — $10 Million Property (Illustrative)

Assumptions (engineering-based study required):

Purchase Price $10,000,000
Land Allocation 15% – basis: $8,500,000
Reclassified Short-Life Asset 30% – $2,550,000 bonus-eligible
Remaining 39-Year Basis $5,950,000 – Year 1 = $152,564

Year 1 Deduction: $2,550,000 (bonus) + $152,564 (regular) = $2,702,564

Tax Bracket Federal Tax Savings (Approximate)
24% $648,615
32% $864,820
37% $999,948
21% (C-Corp) $567,539

Example — $25 Million Property (Illustrative)

Purchase Price $25,000,000
Land Allocation 15% – basis: $21,250,000
Reclassified Short-Life Asset 30% – $6,375,000 bonus-eligible
Remaining 39-Year Basis $14,875,000 – Year 1 = $381,410

Year 1 Deduction: $6,375,000 (bonus) + $381,410 (regular) = $6,756,410

Tax Bracket Federal Tax Savings (Approximate)
24% $1,621,538
32% $2,162,051
37% $2,500,871
21% (C-Corp) $1,418,846
179D Energy Deduction – Quick Screen
  • Who Qualifies: commercial buildings and major retrofits, “designer” rule applies to gov and non profits.
  • Eligible Systems: Envelope, HVAC/HW and lighting meeting ASHRAE standards and certification.
  • Inputs needed: Plans/specs, sq ft, system types, service date and wage/apprenticeship status.
  • Result: per-sq-ft deduction that stacks with bonus depreciation and cost segregation.

Reusable Walls (GreenZip™) — §1245 Personal Property

Non-load-bearing, demountable partitions and related finishes qualify as §1245 personal property (typically 5-year) and may receive 100 % bonus depreciation when placed in service. Classification is verified in the engineering study.

GreenZip™ uses a tape-only, reusable drywall system (patented) that reduces tear-out waste and supports §1245 classification for accelerated depreciation.

Form 3115 Look-Back & §481(a) Catch-Up

Owners of buildings purchased before 2025 can retroactively claim missed depreciation through a Change in Accounting Method (Form 3115). The §481(a) adjustment provides a one-time catch-up deduction without amending prior returns — often producing hundreds of thousands in immediate cash-flow benefits.

Nicola J. (Nick) Coppola — CRE Tax & Sustainability Strategist
[email protected](919) 632-0133TaxLogicCRE.com

Tax Logic™ collaborates with CSSI for certified cost-segregation studies. Informational only — not tax advice. All figures illustrative; final results depend on engineering scope and placed-in-service timing.

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about Nick Coppola
Nick Coppola

Nick Coppola helps commercial real estate investors and developers unlock smarter, more tax efficient ways to build and grow value. He specializes in cost segregation, 179D energy dedications and after-tax ROI strategies across hospitality, healthcare and multi family projects.