n-08-25.pdf

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Part III – Administrative, Procedural, and Miscellaneous

GO Zone Bonus Depreciation Recapture

Notice 2008-25

SECTION 1. PURPOSE
This notice provides guidance with respect to the recapture of the 50-percent
additional first year depreciation deduction provided by § 1400N(d) of the Internal
Revenue Code (GO Zone additional first year depreciation deduction) for qualified Gulf
Opportunity Zone property (GO Zone property), including specified Gulf Opportunity
Zone extension property (GO Zone extension property). Specifically, this notice
explains how the recapture rules described in section 6 of Notice 2006-77, 2006-40
I.R.B. 590, apply to GO Zone property that is relinquished in a like-kind exchange or as
a result of an involuntary conversion.
SECTION 2. BACKGROUND AND GO ZONE PROPERTY
.01 Section 1400N(d) generally allows a 50-percent additional first year
depreciation deduction for GO Zone property. The GO Zone additional first year
depreciation deduction is allowable in the taxable year in which the GO Zone property is
placed in service by the taxpayer. The computation of the allowable GO Zone
additional first year depreciation deduction and the otherwise allowable depreciation
deduction for GO Zone property (including GO Zone extension property) is made in
accordance with rules similar to the rules for 50-percent bonus depreciation property in

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§ 1.168(k)-1(d)(1)(i), (1)(iii), and (2) of the Income Tax Regulations. Further, rules
similar to the special rules in § 1.168(k)-1(f) apply for purposes of the GO Zone
additional first year depreciation deduction.
.02 GO Zone property is depreciable property that meets all of the requirements
in § 1400N(d)(2) and in section 2.02 of Notice 2006-77, as clarified, modified, and
amplified by section 5 of Notice 2007-36, 2007-17 I.R.B. 1000. GO Zone extension
property is depreciable property that meets all of the requirements in § 1400N(d)(6)(B)
and in section 4 of Notice 2007-36. One of the requirements of GO Zone property and
GO Zone extension property is that substantially all of the use of the property must be in
the GO Zone and in the active conduct of a trade or business by the taxpayer in the GO
Zone. Section 3.01 of Notice 2006-77 defines the term “substantially all” as meaning 80
percent or more during each taxable year. Depreciable property described in
§ 1400N(d)(2)(B) and in section 2.03 of Notice 2006-77 is not eligible for the GO Zone
additional first year depreciation deduction.
.03 The counties and parishes in Alabama, Louisiana, and Mississippi that
comprise the GO Zone are listed on page 2 of IRS Publication 4492, Information for
Taxpayers Affected by Hurricanes Katrina, Rita, and Wilma, under Gulf Opportunity
(GO) Zone (Core Disaster Area).
.04 Section 1400N(d)(5) provides that for purposes of § 1400N(d), rules similar to
the recapture rules under § 179(d)(10) apply with respect to any GO Zone property that
ceases to be GO Zone property. Section 6 of Notice 2006-77 provides the rules for
applying the recapture requirement described in § 1400N(d)(5). The Treasury
Department and the Internal Revenue Service have learned that taxpayers are

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uncertain how to apply these recapture rules to GO Zone property (including GO Zone
extension property) relinquished by a taxpayer in a like-kind exchange under § 1031 or
as a result of an involuntary conversion under § 1033. This notice clarifies the
application of the recapture rule in § 1400N(d)(5) to such property.
SECTION 3. RECAPTURE RULES UNDER § 1400N(d)(5)
.01 In General
. Section 1400N(d)(5) provides that for purposes of § 1400N(d),
rules similar to the recapture rules under § 179(d)(10) and § 1.179-1(e) apply with
respect to any GO Zone property that ceases to be GO Zone property. For example,
GO Zone property will cease to be GO Zone property when the property is no longer
substantially used in the GO Zone or in the active conduct of a trade or business by the
taxpayer in the GO Zone. For purposes of this section 3, GO Zone property also
includes GO Zone extension property.
.02 Application
.
(1) In general
. Except as provided in section 3.02(2) or (3) of this notice, if GO
Zone property is no longer GO Zone property in the hands of the same taxpayer at any
time before the end of the GO Zone property’s recovery period as determined under
§ 167(f)(1) or § 168, as applicable, then the taxpayer must recapture in the taxable year
in which the GO Zone property is no longer GO Zone property (the recapture year) the
benefit derived from claiming the GO Zone additional first year depreciation deduction
for such property. The benefit derived from claiming the GO Zone additional first year
depreciation deduction for the property is equal to the excess of the total depreciation
claimed (including the GO Zone additional first year depreciation deduction) for the
property for the taxable years before the recapture year over the total depreciation that

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would have been allowable for the taxable years before the recapture year as a
deduction under § 167(f)(1) or § 168, as applicable, had the GO Zone additional first
year depreciation deduction not been claimed (regardless of whether such excess
reduced the taxpayer’s tax liability). The amount to be recaptured is treated as ordinary
income for the recapture year. For the recapture year and subsequent taxable years,
the taxpayer’s deductions under § 167(f)(1) or § 168, as applicable, are determined as if
no GO Zone additional first year depreciation deduction was claimed with respect to the
property. If, subsequent to the recapture year, a change in the use of the property
results in the property again being GO Zone property, then the GO Zone additional first
year depreciation deduction is not allowable for the property.
(2) Coordination of recapture rules with § 1245 and § 1250
. Except as
provided in section 3.02(3) of this notice, there is no recapture under this section 3 if §
1245(a) or § 1250(a) applies to the disposition of the property.
(3) Application of recapture rules in a like-kind exchange or involuntary
conversion.
(a) If GO Zone property is transferred by a taxpayer in a like-kind exchange or
as a result of an involuntary conversion (relinquished property) and the property
acquired by the taxpayer in the like-kind exchange or involuntary conversion
(replacement property) is GO Zone property in the hands of the taxpayer, there is no
recapture under section 3.02(1) of this notice.
(b) If GO Zone property is transferred by a taxpayer in a like-kind exchange
or as a result of an involuntary conversion (relinquished property) and the replacement
property is not GO Zone property in the hands of the taxpayer and is not substantially

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used in the GO Zone or in the active conduct of a trade or business by the taxpayer in
the GO Zone, there is recapture under section 3.02(1) of this notice. The amount to be
recaptured and the resulting increase in basis under section 3.02(1) of this notice are
determined before the application of § 1031, § 1033, § 1245, or § 1250. For purposes
of this section 3.02(3), the term “substantially” means 80 percent or more during each
taxable year.
(c) If GO Zone property is transferred by a taxpayer in a like-kind exchange
or as a result of an involuntary conversion (relinquished property) and the replacement
property is not GO Zone property in the hands of the taxpayer but is substantially used
in the GO Zone and in the active conduct of a trade or business by the taxpayer in the
GO Zone, there is no recapture under section 3.02(1) of this notice. However, if after
the acquisition of the replacement property, that property ceases to be substantially
used in the GO Zone or in the active conduct of a trade or business by the taxpayer in
the GO Zone, there is recapture under section 3.02(1) of this notice. Similarly, there is
recapture under section 3.02(1) of this notice if, after the acquisition of the replacement
property, that property is transferred by the taxpayer in another like-kind exchange or
another involuntary conversion and the subsequent replacement property is not GO
Zone property in the hands of the taxpayer and is not substantially used in the GO Zone
or in the active conduct of a trade or business by the taxpayer in the GO Zone.
If there is recapture under section 3.02(1) of the notice pursuant to this section
3.02(3)(c), the recapture year is the first taxable year in which the replacement property
(or subsequent replacement property) ceases to be substantially used in the GO Zone
or in the active conduct of a trade or business by the taxpayer in the GO Zone. In

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determining the benefit derived from claiming the GO Zone additional first year
depreciation deduction, the depreciation of both the relinquished property and
replacement property is taken into account.
.03 Examples
. The following examples illustrate the provisions of this section 3.
(a) Example 1. H, a calendar-year taxpayer, owns and operates a furniture
store in the GO Zone. In December 2006, H purchases a new delivery truck for
$50,000 and places it in service for use in H's business. For 2006, this delivery truck is
GO Zone property and is 5-year property under § 168(e). H
depreciates its 5-year
property placed in service in 2006 using the optional depreciation table that corresponds
with the general depreciation system, the 200-percent declining balance method, a 5-
year recovery period, and the half-year convention. During 2007, the delivery truck is
used less than 80 percent in the GO Zone.
(i) For 2006, H
is allowed the GO Zone additional first year depreciation
deduction of $25,000 for the delivery truck (unadjusted depreciable basis of $50,000
multiplied by .50). In addition, H
's depreciation deduction allowable in 2006 for the
remaining adjusted depreciable basis of $25,000 for the delivery truck (the unadjusted
depreciable basis of $50,000 reduced by the GO Zone additional first year depreciation
deduction of $25,000) is $5,000 (the remaining adjusted depreciable basis of $25,000
multiplied by the annual depreciation rate of .20 for recovery year 1). Thus, H
's
depreciation deduction allowable in 2006 for the delivery truck totals $30,000.
(ii) For 2007, because the delivery truck does not meet the substantially all
(80 percent) requirement described in section 3.01 of Notice 2006-77, the delivery truck
is no longer GO Zone property. Accordingly, for 2007, H
must recapture as ordinary

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income $20,000 ($30,000 depreciation claimed by H for the truck before 2007 less the
$10,000 depreciation that would have been allowable for the truck before 2007 had the
GO Zone additional first year depreciation deduction not been claimed (unadjusted
depreciable basis of $50,000 multiplied by the cumulative annual depreciation rate of
.20 before 2007)). In addition, H
's depreciation deduction allowable in 2007 for the
delivery truck is $16,000 (unadjusted depreciable basis of $50,000 multiplied by the
annual depreciation rate of .32 for recovery year 2) (determined as if no GO Zone
additional first year depreciation deduction was claimed for the truck).
(b) Example 2
. Assume the same facts as in Example 1, except that during
2008, the delivery truck is used 80 percent or more in the GO Zone. The GO Zone
additional first year depreciation deduction is not allowable for the delivery truck even
though the truck is GO Zone property in the hands of H
in 2008. Thus, H's depreciation
deduction allowable in 2008 for the delivery truck is $9,600 (unadjusted depreciable
basis of $50,000 multiplied by the annual depreciation rate of .1920 for recovery year 3)
(determined as if no GO Zone additional first year depreciation deduction was claimed
for the truck).
(c) Example 3
. J, a calendar-year taxpayer, owns and operates a
manufacturing plant in the GO Zone. In January 2007, J
purchases new equipment for
$100,000 and places it in service for use in J
’s business. The equipment is GO Zone
property and is 5-year property under § 168(e). J depreciates its 5-year property placed
in service in 2007 using the optional depreciation table that corresponds with the
general depreciation system, the 200-percent declining balance method of depreciation,

8
a 5-year recovery period, and the half-year convention. During 2008, J sells the
equipment for $65,000.
(i) For 2007, J
is allowed the GO Zone additional first year depreciation
deduction of $50,000 for the equipment (unadjusted depreciable basis of $100,000
multiplied by .50). In addition, J
's depreciation deduction allowable in 2007 for the
remaining adjusted depreciable basis of $50,000 for the equipment (the unadjusted
depreciable basis of $100,000 reduced by the GO Zone additional first year
depreciation deduction of $50,000) is $10,000 (the remaining adjusted depreciable
basis of $50,000 multiplied by the annual depreciation rate of .20 for recovery year 1).
Thus, J
's depreciation deduction allowable in 2007 for the equipment totals $60,000.
(ii) For 2008, because the equipment is sold and § 1245(a) applies to this
sale, there is no recapture under section 3.02(1) of this notice pursuant to section
3.02(2) of this notice. In addition, because the half-year convention applies to the
equipment, J
is entitled to ½ of the depreciation deduction allowable for 2008. Thus, J’s
depreciation deduction allowable in 2008 for the equipment is $8,000 (one half of the
remaining adjusted depreciable basis of $50,000 multiplied by the annual depreciation
rate of .32 for recovery year 2). Consequently, the adjusted basis of the equipment for
determining gain or loss is $32,000 (the unadjusted depreciable basis of $100,000 less
the depreciation deduction allowable for 2007 and 2008 totaling $68,000). Accordingly,
J
recognizes gain of $33,000 from the sale of the equipment. All of this recognized gain
is ordinary income pursuant to § 1245(a).
(d) Example 4. K, a calendar-year taxpayer, owns and operates restaurants.
In February 2007, K
completed construction of a new building in New Orleans (New

9
Orleans building) and placed it in service for use in K’s business. The total cost of the
building is $4,000,000. For 2007, the New Orleans building is GO Zone property and is
nonresidential real property under § 168(e). K
depreciates its nonresidential real
property placed in service in 2007 using the optional depreciation table that corresponds
with the general depreciation system, the straight-line method of depreciation, a 39-year
recovery period, and the mid-month convention. In March 2008, K
exchanges the New
Orleans building for a new building in Hancock County, Mississippi (Hancock building),
in a transaction described in § 1031(a). The Hancock building is placed in service by K

in March 2008 for use in K’s business, is GO Zone property in the hands of K, and is
nonresidential real property under § 168(e).
(i) For 2007, K is allowed the GO Zone additional first year depreciation
deduction for the New Orleans building in the amount of $2,000,000 (unadjusted
depreciable basis of $4,000,000 multiplied by .50). In addition, K
's depreciation
deduction allowable in 2007 for the remaining adjusted depreciable basis of $2,000,000
(the unadjusted depreciable basis of $4,000,000 reduced by the GO Zone additional
first year depreciation deduction of $2,000,000) is $44,940 (the remaining adjusted
depreciable basis of $2,000,000 multiplied by the annual depreciation rate of .02247 for
the 2
nd
month in recovery year 1). Thus, K's depreciation deduction allowable in 2007
for the New Orleans building totals $2,044,940.
(ii) For 2008, because K
exchanged GO Zone property for GO Zone property,
there is no recapture under section 3.02(1) of this notice pursuant to section 3.02(3)(a)
of this notice. Thus, for 2008, pursuant to § 1.168(i)-6(e)(2)(i), the depreciation
deduction allowable for the New Orleans building is $10,683 (the remaining adjusted

10
depreciable basis of $2,000,000 multiplied by the annual depreciation rate of .02564 for
the recovery year 2, multiplied by 2.5/12). Consequently, the adjusted depreciable
basis of the New Orleans building at the time of the like-kind exchange is $1,944,377
(unadjusted depreciable basis of $4,000,000, less the depreciation deduction allowable
of $2,044,940 in 2007, less the depreciation deduction allowable of $10,683 in 2008).
(iii) For 2008, because the Hancock building is GO Zone property in the
hands of K
, K is allowed the GO Zone additional first year depreciation deduction for the
Hancock building in the amount of $972,189 (depreciable exchanged basis of
$1,944,377 multiplied by .50). K
decides to use the optional depreciation table to
calculate depreciation on the depreciable exchanged basis of the Hancock building.
Consequently, pursuant to § 1.168(i)-6(e)(2)(ii), K's depreciation deduction allowable in
2008 for the remaining depreciable exchanged basis of $972,188 (the depreciable
exchanged basis of $1,944,377 reduced by the GO Zone additional first year
depreciation deduction of $972,189) is $20,188 (the remaining depreciable exchanged
basis of $972,188 multiplied by the annual depreciation rate of .02564 for the recovery
year 2 as modified by the transaction coefficient of 1.0230 [1 / (1 - .02247)], multiplied
by 9.5/12). Thus, K
's depreciation deduction allowable in 2008 for the Hancock building
totals $992,377.
(e) Example 5
. Assume the same facts as in Example 4, except that in March
2008, K exchanges the New Orleans building for a new building in Maryland (Maryland
building), in a transaction described in § 1031(a). The Maryland building is placed in
service by K in March 2008 for use in K’s business and is nonresidential real property
under § 168(e).

11
(i) Because Maryland is not in the GO Zone, the Maryland building is not GO
Zone property and is not substantially used in the GO Zone and in the active conduct of
a trade or business by K
in the GO Zone. Thus, pursuant to section 3.02(3)(b) of this
notice, there is recapture under section 3.02(1) of this notice of the benefit derived from
claiming the GO Zone additional first year depreciation deduction for the New Orleans
building. Consequently, for 2008, K
must recapture as ordinary income $1,955,060
($2,044,940 depreciation claimed by K for the New Orleans building before 2008 less
the $89,880 depreciation that would have been allowable for the New Orleans building
before 2008 had the GO Zone additional first year depreciation deduction not been
claimed (unadjusted depreciable basis of $4,000,000 multiplied by the cumulative
annual depreciation rate of .02247 before 2008)). In addition, pursuant to § 1.168(i)-
6(e)(2)(i), K
's depreciation deduction allowable in 2008 for the New Orleans building is
$21,367 (the unadjusted depreciable basis of $4,000,000 multiplied by the annual
depreciation rate of .02564 for the recovery year 2, multiplied by 2.5/12) (determined as
if no GO Zone additional first year depreciation deduction was claimed for the New
Orleans building). The adjusted depreciable basis of the New Orleans building at the
time of the like-kind exchange is $3,888,753 (unadjusted depreciable basis of
$4,000,000, less the depreciation deduction allowable of $2,044,940 in 2007, plus the
recapture amount of $1,955,060 in 2008, less the depreciation deduction allowable of
$21,367 in 2008).
(ii) For 2008, because the Maryland building is not GO Zone property, K
is
not allowed the GO Zone additional first year depreciation deduction for the Maryland
building. K
decides to use the optional depreciation table to calculate depreciation on

12
the depreciable exchanged basis of the Maryland building. Thus, pursuant to § 1.168(i)-
6(e)(2)(ii), K's depreciation deduction allowable in 2008 for the depreciable exchanged
basis of $3,888,753 for the Maryland building is $80,751 (the depreciable exchanged
basis of $3,888,753 multiplied by the annual depreciation rate of .02564 for the recovery
year 2 as modified by the transaction coefficient of 1.0230 [1 / (1 - .02247)], multiplied
by 9.5/12).
(f) Example 6
. Assume the same facts as in Example 4, except the Hancock
building is not a new building, but a building that has been used by another taxpayer in
its business since 2003. As a result, the Hancock building is not GO Zone property.
(i) Even though the Hancock building is not GO Zone property, the Hancock
building is substantially used in the GO Zone and in the active conduct of a trade or
business by K
in the GO Zone. Consequently, pursuant to section 3.02(3)(c) of this
notice, there is no recapture under section 3.02(1) of this notice with respect to the New
Orleans building. Thus, for 2008, pursuant to § 1.168(i)-6(e)(2)(i), the depreciation
deduction allowable for the New Orleans building is $10,683 (the remaining adjusted
depreciable basis of $2,000,000 multiplied by the annual depreciation rate of .02564 for
the recovery year 2, multiplied by 2.5/12). Consequently, the adjusted depreciable
basis of the New Orleans building at the time of the like-kind exchange is $1,944,377
(unadjusted depreciable basis of $4,000,000, less the depreciation deduction allowable
of $2,044,940 in 2007, less the depreciation deduction allowable of $10,683 in 2008).
(ii) For 2008, because the Hancock building is not GO Zone property, K
is not
allowed the GO Zone additional first year depreciation deduction for the Hancock
building. K
decides to use the optional depreciation table to calculate depreciation on

13
the depreciable exchanged basis of the Hancock building. Thus, pursuant to § 1.168(i)-
6(e)(2)(ii), K's depreciation deduction allowable for 2008 for the depreciable exchanged
basis of $1,944,377 is $40,375 (the depreciable exchanged basis of $1,944,377
multiplied by the annual depreciation rate of .02564 for the recovery year 2 as modified
by the transaction coefficient of 1.0230 [1 / (1 - .02247)], multiplied by 9.5/12).
(g) Example 7
. Assume the same facts as in Example 6, except that in March
2009, K exchanges the Hancock building for a new building in Texas (Texas building),
in a transaction described in § 1031(a). The Texas building is placed in service by K
in
March 2009 for use in K’s business and is nonresidential real property under § 168(e).
(i) Because Texas is not in the GO Zone, the Texas building is not GO Zone
property and is not substantially used in the GO Zone and in the active conduct of a
trade or business by K
in the GO Zone. Consequently, pursuant to section 3.02(3)(c) of
this notice, K’s exchange of the Hancock building (the replacement property) for the
Texas building (subsequent replacement property) causes K
to recapture the benefit
derived from claiming the GO Zone additional first year depreciation deduction for the
New Orleans building under section 3.02(1) of this notice. Thus, for 2009, K
must
recapture as ordinary income $1,904,000 ($2,095,998 depreciation claimed by K
for the
New Orleans and Hancock buildings before 2009 less the $191,998 depreciation that
would have been allowable for the New Orleans and Hancock buildings before 2009
had the GO Zone additional first year depreciation deduction not been claimed, which is
the total of the amounts as determined in (a) and (b) below ($89,880 for the 2007
depreciation allowable for the New Orleans building, plus $21,367 for the 2008

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depreciation allowable for the New Orleans building, plus $80,751 for the 2008
depreciation allowable for the Hancock building)):
(a) For the New Orleans building, the depreciation that would have been
allowable for the New Orleans building in 2007 had the GO Zone additional first year
depreciation deduction not been claimed is $89,880 (unadjusted depreciable basis of
$4,000,000 multiplied by the annual depreciation rate of .02247 for the 2
nd
month for
recovery year 1). In addition, pursuant to § 1.168(i)-6(e)(2)(i), K's depreciation that
would have been allowable for the New Orleans building in 2008 had the GO Zone
additional first year depreciation deduction not been claimed in 2007 is $21,367 (the
unadjusted depreciable basis of $4,000,000 multiplied by the annual depreciation rate of
.02564 for the recovery year 2, multiplied by 2.5/12). The adjusted depreciable basis of
the New Orleans building at the time of the like-kind exchange (determined as if no GO
Zone additional first year depreciation deduction was claimed for the New Orleans
building) is $3,888,753 (unadjusted depreciable basis of $4,000,000, less the
depreciation deduction allowable of $89,880 in 2007, less the depreciation deduction
allowable of $21,367 in 2008).
(b) For the Hancock building, K
’s depreciable exchanged basis would have
been $3,888,753 if the GO Zone additional first year depreciation deduction was not
claimed for the New Orleans building. Thus, pursuant to § 1.168(i)-6(e)(2)(ii), K
's
depreciation deduction allowable in 2008 for the depreciable exchanged basis of
$3,888,753 for the Hancock building is $80,751 (the depreciable exchanged basis of
$3,888,753 multiplied by the annual depreciation rate of .02564 for the recovery year 2
as modified by the transaction coefficient of 1.0230 [1 / (1 - .02247)], multiplied by

15
9.5/12) (determined as if no GO Zone additional first year depreciation deduction was
claimed for the New Orleans building).
(ii) For 2009, K
's depreciation deduction allowable for the Hancock building,
pursuant to § 1.168(i)-6(e)(2)(i), is $21,250 (the depreciable exchanged basis of
$3,888,753 multiplied by the annual depreciation rate of .02564 for the recovery year 3
as modified by the transaction coefficient of 1.0230 [1/ (1 - .02247)], multiplied by
2.5/12) (determined as if no GO Zone additional first year depreciation deduction was
claimed for the New Orleans building). Thus, the adjusted depreciable basis of the
Hancock building at the time of the like-kind exchange for the Texas building is
$3,786,752 (depreciable exchanged basis of $3,888,753, less the depreciation
deduction allowable of $80,751 in 2008, less the depreciation deduction allowable of
$21,250 in 2009) (determined as if no GO Zone additional first year depreciation
deduction was claimed for the New Orleans building).
(iii) For 2009, K
decides to use the optional depreciation table to calculate
depreciation on the depreciable exchanged basis of the Texas building. Thus, pursuant
to § 1.168(i)-6(e)(2)(ii), K
's depreciation deduction allowable in 2009 for the depreciable
exchanged basis of $3,786,752 for the Texas building is $80,746 (the depreciable
exchanged basis of $3,786,752 multiplied by the annual depreciation rate of .02564 for
the recovery year 3 as modified by the transaction coefficient of 1.0505 [1 / (1 -
.02247+.02564)], multiplied by 9.5/12).
SECTION 4. EFFECT ON OTHER DOCUMENTS
Section 6 of Notice 2006-77, 2006-40 I.R.B. 590, is clarified and amplified to read
as provided in section 3 of this notice.

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SECTION 5. EFFECTIVE DATE
This notice is effective February 11, 2008.
SECTION 6. DRAFTING INFORMATION
The principal author of this notice is Ruba Nasrallah of the Office of Associate
Chief Counsel (Income Tax & Accounting). For further information regarding this notice,
contact Ms. Nasrallah or Douglas Kim at (202) 622-4930 (not a toll-free call).