Is bonus depreciation coming back? Yes. Bonus depreciation has not only returned but is now a permanent provision of the tax code at 100% for qualified property acquired and placed in service after January 19, 2025, thanks to the One Big Beautiful Bill Act signed into law on July 4, 2025.
Key Takeaways
- The One Big Beautiful Bill Act permanently restored 100% bonus depreciation for property acquired after January 19, 2025
- The previous phase-out schedule that would have dropped bonus depreciation to zero by 2027 has been completely eliminated
- Cost segregation studies can now deliver even greater tax savings by identifying short-lived assets eligible for immediate 100% write-offs
- State tax treatment varies significantly – not all states conform to federal bonus depreciation rules
- Section 179 limits increased to $2.5 million with a $4 million phase-out threshold
The Return That Nobody Expected This Fast
Let me tell you something most tax advisors won’t admit. When bonus depreciation started its phase-out back in 2023, dropping from 100% to 80%, then 60% in 2024, we all figured it was gone for good. The tax world braced for a slow death march to zero by 2027.
Then July 4, 2025 happened.
President Trump signed the One Big Beautiful Bill Act into law, and just like that, the game changed completely. Not just a temporary extension. Not just slowing down the phase-out. A full, permanent restoration of 100% bonus depreciation for qualifying assets.
Here’s what that means in plain English: if you buy equipment, machinery, or make certain building improvements after January 19, 2025, you can write off the entire cost in year one. Every penny. The IRS isn’t asking you to spread that deduction over 5, 7, or 15 years anymore.
This isn’t just a tax break. It’s a cash flow revolution for businesses willing to invest in their growth.
What Changed (And Why It Matters to Your Bottom Line)
The Tax Cuts and Jobs Act of 2017 gave us 100% bonus depreciation through 2022. Great while it lasted. But the law included a sunset provision – a fancy term for “this good thing will end.” Starting in 2023, the percentage dropped by 20 points each year. By early 2025, businesses could only deduct 40% of qualifying purchases in year one.
That 40% rate lasted exactly 19 days in 2025.
The One Big Beautiful Bill Act wiped out the entire phase-out schedule. Property placed in service between January 1 and January 19, 2025 gets the 40% rate. Everything after that? Full 100%. And unlike the original TCJA provision, there’s no expiration date this time.
The Mechanics Most People Miss
Congress structured this carefully. The effective date is tied to two things: acquisition date and placed-in-service date. Both must occur after January 19, 2025 to get the full 100% benefit. If you signed a binding contract to buy a warehouse on January 15, 2025, even if you don’t take possession until March, you’re stuck with the 40% rate.
That timing detail has already cost businesses millions in lost deductions because they didn’t understand the rules.
The Types of Property That Qualify
Not everything qualifies for bonus depreciation. The property must be MACRS property with a recovery period of 20 years or less. That includes:
Machinery and equipment, computers and software, vehicles (with some weight restrictions), furniture and fixtures, land improvements like parking lots and fencing, and qualified improvement property for commercial buildings. What doesn’t qualify? Land itself, buildings with a recovery period longer than 20 years, and property you owned before.
Used equipment counts too, as long as you’ve never used it before and didn’t buy it from a related party. That opens up significant opportunities for businesses buying pre-owned assets.
Quick Decision Guide: Should You Use Bonus Depreciation?
| Your Situation | Use 100% Bonus | Consider Regular Depreciation |
|---|---|---|
| High taxable income this year | ✓ Maximize deductions now | |
| Expecting higher tax rates in future | ✓ Save deductions for later | |
| Need immediate cash flow | ✓ Reduce tax bill instantly | |
| Operating in non-conforming state | ✓ Avoid state tax complications | |
| Making large capital purchases | ✓ Write off entire cost now | |
| Low income / generating NOLs | ✓ Spread deductions over time |
Cost Segregation: The Secret Weapon Most Businesses Ignore
Here’s where things get interesting. Most building purchases get depreciated over 27.5 years for residential or 39 years for commercial property. That’s a tiny annual deduction.
A cost segregation study changes everything.
This engineering-based analysis breaks your building into components. Instead of treating the whole structure as one asset, it identifies the parts that qualify as personal property or land improvements – things with 5, 7, or 15-year recovery periods.
Carpet, lighting fixtures, decorative molding, parking lots, landscaping, HVAC components, electrical systems serving equipment. These items hide inside your building purchase, and most business owners never separate them out.
Now that bonus depreciation is back at 100%, every dollar you reclassify through cost segregation gets written off immediately. Not spread over decades. Year one.
Real Numbers From Real Properties
Buy a $5 million commercial building. Without cost segregation, you depreciate it over 39 years – about $128,000 per year. Run a proper cost segregation study, and you might reclassify $1.2 million into shorter-lived assets. That entire $1.2 million becomes eligible for 100% bonus depreciation in year one.
At a 37% tax rate, that’s a $444,000 tax savings in year one instead of spreading it over 39 years. The time value of money alone makes this decision obvious.
The Professional Component Nobody Talks About
The IRS scrutinizes cost segregation studies heavily. You can’t just guess which building components qualify or make up percentages. You need detailed engineering analysis, proper documentation, and defendable allocations.
I’ve seen business owners try DIY cost segregation studies. The IRS rejected every one I came across. Then they faced penalties on top of the lost deductions.
Sean Graham, CPA and founder of Maven Cost Segregation, puts it this way: “100% bonus depreciation is now permanently restored. This changes how clients should plan for 2025 and beyond. It’s not about chasing deductions just for the sake of it, it’s about applying the tax code strategically so your clients capture these benefits compliantly and thoughtfully.”
Five Critical Facts Every Business Owner Needs to Know
- Timing is everything: Both your purchase contract and placed-in-service date must fall after January 19, 2025 to qualify for 100% bonus depreciation
- State rules differ dramatically: Many states don’t conform to federal bonus depreciation, requiring add-backs on state returns that can create unexpected tax bills
- You can elect out: Bonus depreciation is automatic unless you explicitly elect out on a class-by-class basis, giving you strategic flexibility
- Cost segregation multiplies the benefit: Without a proper study, you’re likely leaving six-figure deductions on the table
- Used property qualifies: You don’t need brand new equipment – pre-owned assets work as long as you meet the acquisition requirements
The State Conformity Problem Nobody Warns You About
Federal law now allows 100% bonus depreciation. Fantastic. But your state? That’s a different story.
States aren’t required to follow federal tax rules. Many deliberately decouple from bonus depreciation provisions to protect state revenue. That means you get the federal deduction but have to add it back on your state return.
California, for example, has historically refused to conform to federal bonus depreciation. New York offers it but with modifications. Tennessee doesn’t allow it at all. Illinois requires businesses to add back 80% of the federal bonus depreciation deduction.
This creates a compliance nightmare. You need to track two sets of basis schedules – one for federal, one for state. When you eventually sell the asset, you’ll have different depreciation recapture amounts for federal versus state purposes.
The Multi-State Business Trap
Operating in multiple states? Each state has different conformity rules. Your $500,000 equipment purchase might generate a full federal deduction, a partial deduction in one state, and zero deduction in another state.
You can’t ignore state conformity issues. State auditors specifically look for businesses taking federal bonus depreciation without making proper state adjustments. The penalties and interest add up fast.
Before making large capital purchases, know your state’s position on bonus depreciation. Factor that into your cash flow projections. A federal tax savings might disappear when you account for state taxes.
Section 179 vs. Bonus Depreciation: The Comparison You Need
| Feature | Section 179 | Bonus Depreciation |
|---|---|---|
| Annual Limit | $2.5 million (2025) | No limit |
| Phase-Out Threshold | Begins at $4 million in purchases | No phase-out |
| Income Limitation | Cannot exceed taxable income | No income limitation |
| Property Types | Tangible personal property, some improvements | Broader range including QIP |
| Used Property | Allowed | Allowed with restrictions |
| State Conformity | Generally better state conformity | Many states decouple |
| Election | Must elect | Automatic unless elect out |
Special Rules for Commercial Real Estate
The One Big Beautiful Bill Act included something new: a 100% depreciation allowance for qualified production property. This covers newly constructed non-residential real estate used for manufacturing, production, or refining tangible personal property in the United States.
This provision runs through 2030. Construction must begin after January 19, 2025 and before January 1, 2029. The property must be placed in service before January 1, 2031.
Why does this matter? Normally, commercial real estate depreciates over 39 years. Under this new rule, qualifying manufacturing facilities can be fully expensed in year one. That’s a game-changer for domestic manufacturing investment.
A $10 million production facility that would normally give you about $256,000 in annual depreciation can now deliver a $10 million deduction in year one. The cash flow impact is massive.
The Qualified Improvement Property Advantage
Interior improvements to commercial buildings – new lighting, flooring, non-structural walls, HVAC upgrades – these count as qualified improvement property with a 15-year recovery period. That means they’re eligible for 100% bonus depreciation.
Restaurant owners renovating a space, retailers updating their stores, office tenants improving their lease space – all of this work generates immediate tax deductions when properly documented.
Case Studies: What This Means in Practice
Manufacturing Company: A mid-sized manufacturer purchased $3 million in equipment in February 2025. Under the old 40% rate (if bought in early January), they’d deduct $1.2 million in year one. With 100% bonus depreciation, they deducted the full $3 million, creating an additional $666,000 in tax savings at a 37% rate.
Commercial Real Estate: A real estate investor bought a $4 million warehouse in March 2025. Cost segregation identified $950,000 in short-lived assets. Without the study, year-one depreciation would be about $103,000. With cost segregation and 100% bonus depreciation, the investor deducted $950,000 immediately – a $313,000 tax benefit in year one.
Planning Strategies for Maximum Impact
Smart business owners don’t just react to tax law changes. They plan around them.
If you’re considering major purchases, timing now matters less than it did during the phase-out period. Bonus depreciation is permanent. You’re not racing a deadline. But that doesn’t mean timing is irrelevant.
The Retroactive Question
What if you bought property in 2023 or 2024? Can you go back and claim 100% bonus depreciation? No. The law isn’t retroactive. Property placed in service before January 20, 2025 is stuck with the phase-out schedule that was in effect when you bought it.
But you might still benefit from a cost segregation study on older properties. Even at 80% (2023) or 60% (2024) bonus depreciation rates, the accelerated deductions can be substantial. And you can file amended returns for prior years if you missed opportunities.
The Income Planning Angle
Not everyone should take 100% bonus depreciation. If your business is generating losses or you expect significantly higher income in future years, regular depreciation might serve you better.
Tax deductions are only valuable if you have income to offset. Creating large net operating losses just moves the tax benefit into the future. Sometimes spreading deductions over multiple years makes more sense.
You can elect out of bonus depreciation on an asset-class basis. That gives you flexibility. Take bonus on some purchases, regular depreciation on others, depending on your income situation each year.
The Professional Guidance You Actually Need
Here’s what separates businesses that maximize these rules from those that don’t: professional expertise.
The IRS doesn’t hand out deductions without documentation. Cost segregation studies require engineering analysis. Asset classifications need support. Placed-in-service dates must be provable. State conformity issues need tracking across multiple jurisdictions.
A qualified cost segregation firm brings engineers who understand construction, accountants who know tax law, and software that tracks every detail the IRS might question. They document everything defensibly.
The cost of a proper study – typically $5,000 to $15,000 for most properties – pays for itself many times over in tax savings. And more importantly, it protects you during an audit.
DIY approaches or cheap online services miss deductions and create audit risks. The IRS can disallow your entire cost segregation study if the methodology doesn’t meet their standards. Then you owe back taxes, penalties, and interest.
Working with a professional cost segregation firm that specializes in bonus depreciation planning ensures you’re compliant while maximizing every available deduction.
What Happens Next
Bonus depreciation is back. Permanently. That’s rare in tax policy – most provisions expire or phase out eventually. This one doesn’t.
For business owners, this creates long-term planning certainty. You can make multi-year capital investment decisions without worrying about the tax rules changing mid-stream.
But don’t wait to act. Even though the deadline pressure is gone, opportunities exist right now. Properties you’re considering, equipment purchases on your radar, building improvements you’ve postponed – all of these decisions just became significantly more tax-advantaged.
The businesses that thrive over the next few years will be the ones that understand these rules and use them strategically. Not just to reduce taxes, but to improve cash flow, accelerate growth investments, and build competitive advantages.
Tax planning isn’t about finding loopholes. It’s about understanding the rules Congress put in place to encourage exactly the kind of investments you’re already planning to make. Bonus depreciation is the government’s way of saying “we want you to invest in your business.”
Take advantage of it. Your competitors certainly will.
Is Bonus Depreciation Coming Back FAQs
Is bonus depreciation really coming back for 2025?
Yes, bonus depreciation has come back permanently at 100% for qualified property acquired and placed in service after January 19, 2025, through the One Big Beautiful Bill Act signed on July 4, 2025.
What property qualifies for the 100% bonus depreciation rate?
Qualified property includes tangible personal property with a MACRS recovery period of 20 years or less, such as machinery, equipment, vehicles, computers, furniture, land improvements, and qualified improvement property for commercial buildings.
Do I need to do anything special to claim bonus depreciation?
Bonus depreciation is automatic for qualifying property unless you elect out on Form 4562, but proper documentation of purchase dates, placed-in-service dates, and asset classifications is essential for IRS compliance.
Will my state allow the same bonus depreciation as federal law?
Not necessarily – many states decouple from federal bonus depreciation rules and require add-backs on state tax returns, so you should verify your specific state’s conformity status before planning around the deduction.
Can I use cost segregation with bonus depreciation for my rental property?
Yes, cost segregation studies identify short-lived building components eligible for 100% bonus depreciation, allowing you to immediately deduct a portion of your building purchase instead of depreciating it over 27.5 or 39 years.
Citations
- Kahn Litwin, “Big Beautiful Bill Restores 100% Bonus Depreciation for 2025”, https://kahnlitwin.com/blogs/tax-blog/big-beautiful-bill-act-restores-100-bonus-depreciation-what-businesses-need-to-know-for-2025
- Comerica Bank, “Bonus depreciation under the One Big Beautiful Bill”, https://www.comerica.com/insights/commercial-banking/assorted-commercial/bonus-depreciation.html
- Whiteman Osterman & Hanna LLP, “Key Depreciation Changes from the ‘One Big Beautiful Bill Act'”, https://www.woh.com/blog/256/Key-Depreciation-Changes-from-the-One-Big-Beautiful-Bill-Act-/
- Sean Graham, CPA Practice Advisor, “What CPAs Should Know About the Return of 100% Bonus Depreciation in 2025”, https://www.cpapracticeadvisor.com/2025/07/09/what-cpas-should-know-about-the-return-of-100-bonus-depreciation-in-2025/164619/
- Holthouse Carlin & Van Trigt, “Cost Segregation + 100% Bonus Depreciation: A Game-Changer for Real Estate Investors”, https://www.hcvt.com/alert-Cost-Segregation
- Bloomberg Tax, “State Conformity to Federal Bonus Depreciation”, https://pro.bloombergtax.com/insights/federal-tax/state-conformity-to-federal-bonus-depreciation/
- Wipfli, “What are the new rules for 100% bonus deduction in 2025”, https://www.wipfli.com/insights/articles/cre-what-are-the-new-rules-for-100-bonus-deduction-in-2025
Paul Kohn MBA is a seasoned business consultant known for helping businesses maximize tax credits and incentives to fuel growth and profitability. He holds a Master’s in Business Administration and has helped numerous companies secure millions in tax credits and implement effective business strategies. He is regarded as a trusted authority for business owners seeking to optimize their savings and growth.