rp-26-15.pdf

us-irs-revenue-procedures-rp-26-15rp-26-15.pdfGuidance

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26 CFR 601.105: Examination of returns and claims for refund, credit, or abatement;
determination of correct tax liability.
(Also Part I, §§ 280F; 1.280F-7.)

Rev. Proc. 2026-15

SECTION 1. PURPOSE
This revenue procedure provides: (1) two tables of limitations on depreciation
deductions for owners of passenger automobiles placed in service by the taxpayer
during calendar year 2026; and (2) a table of dollar amounts that must be used to
determine income inclusions by lessees of passenger automobiles with a lease term
beginning in calendar year 2026. These tables reflect the automobile price inflation
adjustments required by § 280F(d)(7) of the Internal Revenue Code (Code).
1
For
purposes of this revenue procedure, the term “passenger automobiles” includes trucks
and vans.
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

1
Unless otherwise specified, all “section” or “§” references are to sections of the Code or the Income Tax
Regulations (26 CFR part 1).

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after 2018, § 280F(d)(7) requires the Internal Revenue Service to increase the amounts
allowable as depreciation deductions by a price inflation adjustment amount that is
determined using the automobile component of the Chained Consumer Price Index for
All Urban Consumers published by the Department of Labor (C-CPI-U).
.02 Section 168(k), as amended by Public Law 119-21, 139 Stat. 72 (July 4, 2025),
commonly known as the One, Big, Beautiful Bill Act (OBBBA), applies to property
acquired and placed in service after January 19, 2025.
2
Section 168(k)(1), as amended
by the OBBBA, allows an additional first year depreciation deduction under § 167(a)
equal to 100 percent of the property’s adjusted basis for the taxable year in which
qualified property, as defined in § 168(k)(2), is placed in service.
Section 168(k), as in effect prior to amendment by the OBBBA (former § 168(k)),
applies to property acquired after September 27, 2017, and before January 20, 2025,
which is placed in service before January 1, 2027. Former section 168(k)(1) provides
that the § 168(k) additional first year depreciation deduction is equal to the applicable
percentage of the property’s adjusted basis. Pursuant to former § 168(k)(6)(A), the
applicable percentage is 100 percent for qualified property placed in service after
September 27, 2017, and before January 1, 2023, and is phased down 20 percent each
year thereafter for property placed in service through December 31, 2026. Accordingly,
the applicable percentage for qualified property acquired after September 27, 2017, and
before January 20, 2025, and placed in service during calendar year 2026 is 20 percent.
For qualified property acquired and placed in service after September 27, 2017,

2
See section 70301(c) of the OBBBA. In determining whether property is acquired after January 19,
2025, for purposes of section 70301(c) of the OBBBA, the taxpayer applies rules consistent with
§§ 1.168(k)-2(b)(5) and 1.1502-68(a) through (d). See section 3.03 of Notice 2026-11, 2026-6 I.R.B. 491.

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§ 168(k)(2)(F)(i) increases the first-year depreciation allowed under § 280F(a)(1)(A)(i)
by $8,000.
.03 Tables 1 and 2 of this revenue procedure provide depreciation limitations for
passenger automobiles placed in service by the taxpayer during calendar year 2026.
Table 1 provides depreciation limitations for passenger automobiles acquired by the
taxpayer after September 27, 2017, and placed in service by the taxpayer during
calendar year 2026, for which the § 168(k) additional first year depreciation deduction
applies. The depreciation limitations in Table 1 apply regardless of whether the
§ 168(k) additional first year depreciation deduction is allowed under former § 168(k) or
§ 168(k) as amended by the OBBBA. Table 2 provides depreciation limitations for
passenger automobiles placed in service by the taxpayer during calendar year 2026 for
which no § 168(k) additional first year depreciation deduction applies. The § 168(k)
additional first year depreciation deduction does not apply for 2026 if the taxpayer:
(1) did not use the passenger automobile during 2026 more than 50 percent for
business purposes; (2) elected out of the § 168(k) additional first year depreciation
deduction pursuant to § 168(k)(7) for the class of property that includes passenger
automobiles; (3) acquired a used passenger automobile and the acquisition of such
property did not meet the acquisition requirements in § 168(k)(2)(E) and § 1.168(k)-
2(b)(3)(iii) of the Income Tax Regulations;
3
or (4) acquired the passenger automobile
before September 28, 2017.
.04 Section 280F(c)(2) requires a reduction to the amount allowable as a deduction

3
For a used passenger automobile acquired after January 19, 2025, the taxpayer applies rules consistent
with the rules in § 1.168(k)-2(b)(3)(iii)
to determine if the property meets the acquisition requirements in
§ 168(k)(2)(E). See section 3.02 of Notice 2026-11, 2026-6 I.R.B. 491.

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to the lessee of a leased passenger automobile. Pursuant to § 280F(c)(3), the
reduction must be substantially equivalent to the limitations on the depreciation
deductions imposed on owners of passenger automobiles. Under § 1.280F-7(a), this
reduction is accomplished by requiring the lessee to include in gross income an amount
determined by applying a formula to a dollar amount obtained from a table.
.05 Table 3 of this revenue procedure provides the dollar amount used by lessees of
passenger automobiles with a lease term beginning in 2026 to determine the income
inclusion amount for those passenger automobiles. The table provides dollar amounts
for a range of passenger automobile fair market values.
SECTION 3. SCOPE
.01 The limitations on depreciation deductions in Tables 1 and 2 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 2026 and
continue to apply for each taxable year that the passenger automobile remains in
service.
.02 The dollar amounts in Table 3 of this revenue procedure apply to leased
passenger automobiles with a lease term beginning in calendar year 2026 and continue
to apply for each taxable year during the lease.
.03 For other recent calendar years, see Rev. Proc. 2021-31, 2021-34 I.R.B. 324, for
passenger automobiles placed in service or leased during calendar year 2021; Rev.
Proc. 2022-17, 2022-13 I.R.B. 930, for passenger automobiles placed in service or
leased during calendar year 2022; Rev. Proc. 2023-14, 2023-6 I.R.B. 466, for
passenger automobiles placed in service or leased during calendar year 2023; Rev.

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Proc. 2024-13, 2024-9 I.R.B. 678, for passenger automobiles placed in service or
leased during calendar year 2024; and Rev. Proc. 2025-16, 2025-11 I.R.B. 1100, for
passenger automobiles placed in service or leased during calendar year 2025.
SECTION 4. APPLICATION
.01 Limitations on Depreciation Deductions for Certain Automobiles.
(1) Amount of the inflation adjustment. Under § 280F(d)(7)(B)(i), the automobile
price inflation adjustment for any calendar year is the percentage (if any) by which the
C-CPI-U automobile component for October of the preceding calendar year exceeds the
automobile component of the CPI (as defined in § 1(f)(4)) for October of 2017, multiplied
by the amount determined under § 1(f)(3)(B). The amount determined under
§ 1(f)(3)(B) is the amount obtained by dividing the new vehicle component of the C-CPI-
U for calendar year 2016 by the new vehicle component of the CPI for calendar year
2016, where the C-CPI-U and the CPI for calendar year 2016 means the average of
such amounts as of the close of the 12-month period ending on August 31, 2016.
Section 280F(d)(7)(B)(ii) defines the term "C-CPI-U automobile component" as the
automobile component of the Chained Consumer Price Index for All Urban Consumers
as described in § 1(f)(6). The product of the October 2017 CPI new vehicle component
(144.868) and the amount determined under § 1(f)(3)(B) (0.694370319) is 100.592.
The new vehicle component of the C-CPI-U released in December 2025 was 124.199
for October 2025. The October 2025 C-CPI-U new vehicle component exceeded the
product of the October 2017 CPI new vehicle component and the amount determined
under § 1(f)(3)(B) by 23.607 (124.199 - 100.592). The percentage by which the C-CPI-
U new vehicle component for October 2025 exceeds the product of the new vehicle

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component of the CPI for October of 2017 and the amount determined under
§ 1(f)(3)(B) is 23.468 percent (23.607/100.592 x 100%), the automobile price inflation
adjustment for 2026 for passenger automobiles. The dollar limitations in § 280F(a) are
therefore multiplied by a factor of 0.23468, and the resulting increases, after rounding to
the nearest $100, are added to the 2018 limitations to give the depreciation limitations
applicable to passenger automobiles for calendar year 2026. This adjustment applies to
all passenger automobiles that are placed in service in calendar year 2026.
(2) Amount of the limitation. Tables 1 and 2 of this revenue procedure contain the
depreciation limitation for each taxable year for passenger automobiles a taxpayer
placed in service during calendar year 2026. Use Table 1 for a passenger automobile
to which the § 168(k) additional first year depreciation deduction applies that is acquired
by the taxpayer after September 27, 2017, and placed in service by the taxpayer during
calendar year 2026. The depreciation limitations in Table 1 apply regardless of whether
the § 168(k) additional first year depreciation deduction is allowed under former § 168(k)
or § 168(k) as amended by the OBBBA. Use Table 2 for a passenger automobile
placed in service by the taxpayer during calendar year 2026 for which no § 168(k)
additional first year depreciation deduction applies.

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REV. PROC. 2026-15 TABLE 1

DEPRECIATION LIMITATIONS FOR PASSENGER AUTOMOBILES ACQUIRED
AFTER SEPTEMBER 27, 2017, AND PLACED IN SERVICE DURING CALENDAR
YEAR 2026, FOR WHICH THE § 168(k) ADDITIONAL FIRST YEAR DEPRECIATION
DEDUCTION APPLIES

Tax Year Amount
1st Tax Year $ 20,300
2nd Tax Year $ 19,800
3rd Tax Year $ 11,900
Each Succeeding Year $ 7,160

REV. PROC. 2026-15 TABLE 2

DEPRECIATION LIMITATIONS FOR PASSENGER AUTOMOBILES
PLACED IN SERVICE DURING CALENDAR YEAR 2026 FOR WHICH NO § 168(k)
ADDITIONAL FIRST YEAR DEPRECIATION DEDUCTION APPLIES

Tax Year Amount
1st Tax Year $ 12,300
2nd Tax Year $ 19,800
3rd Tax Year $ 11,900
Each Succeeding Year $ 7,160

.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 with a lease term beginning in calendar
year 2026. In applying these procedures, lessees of passenger automobiles should use
Table 3 of this revenue procedure.

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REV. PROC. 2026-15 TABLE 3

DOLLAR AMOUNTS FOR PASSENGER AUTOMOBILES
WITH A LEASE TERM BEGINNING IN CALENDAR YEAR 2026

Fair Market
Value of
Passenger
Automobile
Over

Fair Market
Value of
Passenger
Automobile

Not Over

1
st
Tax
Year
During
Lease

2
nd
Tax
Year
During
Lease

3
rd
Tax
Year
During
Lease

4
th
Tax
Year
During
Lease

5
th
Tax
Year
During
Lease &
Later

$62,000 $64,000 8 15 21 25 27
64,000 66,000 19 38 56 66 76
66,000 68,000 29 62 91 108 123
68,000 70,000 40 86 125 149 172
70,000 72,000 51 109 160 191 220
72,000 74,000 61 133 195 232 268
74,000 76,000 72 156 230 274 316
76,000 78,000 83 179 265 316 364
78,000 80,000 93 203 299 358 412
80,000 85,000 112 244 360 431 496
85,000 90,000 139 302 447 535 617
90,000 95,000 166 361 534 639 737
95,000 100,000 192 420 621 743 858
100,000 110,000 232 507 752 900 1,038
110,000 120,000 286 624 926 1,108 1,279
120,000 130,000 339 742 1,099 1,317 1,520
130,000 140,000 392 859 1,273 1,526 1,760
140,000 150,000 446 976 1,447 1,734 2,001
150,000 160,000 499 1,093 1,621 1,943 2,242
160,000 170,000 553 1,210 1,795 2,151 2,483
170,000 180,000 606 1,328 1,968 2,360 2,723
180,000 190,000 659 1,445 2,142 2,569 2,964
190,000 200,000 713 1,562 2,316 2,777 3,205
200,000 210,000 766 1,679 2,490 2,986 3,445
210,000 220,000 820 1,796 2,664 3,194 3,686
220,000 230,000 873 1,913 2,838 3,403 3,927
230,000 240,000 926 2,031 3,012 3,610 4,168
240,000 250,000 980 2,148 3,185 3,820 4,408
250,000 260,000 1,033 2,265 3,360 4,027 4,650
260,000 270,000 1,086 2,382 3,534 4,236 4,890
270,000 280,000 1,140 2,499 3,708 4,444 5,131
280,000 290,000 1,193 2,617 3,881 4,653 5,372
$290,000 $300,000 1,247 2,733 4,056 4,862 5,612

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Fair Market
Value of
Passenger
Automobile
Over

Fair Market
Value of
Passenger
Automobile

Not Over

1
st
Tax
Year
During
Lease

2
nd
Tax
Year
During
Lease

3
rd
Tax
Year
During
Lease

4
th
Tax
Year
During
Lease

5
th
Tax
Year
During
Lease &
Later

300,000 310,000 1,300 2,851 4,229 5,070 5,854
310,000 320,000 1,353 2,968 4,403 5,279 6,094
320,000 330,000 1,407 3,085 4,577 5,487 6,335
330,000 340,000 1,460 3,202 4,751 5,696 6,576
340,000 350,000 1,514 3,319 4,925 5,904 6,817
350,000 360,000 1,567 3,437 5,098 6,113 7,057
360,000 370,000 1,620 3,554 5,273 6,321 7,298
370,000 380,000 1,674 3,671 5,446 6,530 7,539
380,000 390,000 1,727 3,788 5,621 6,738 7,779
390,000 400,000 1,781 3,905 5,794 6,947 8,020
400,000 410,000 1,834 4,022 5,969 7,155 8,261
410,000 420,000 1,887 4,140 6,142 7,364 8,501
420,000 430,000 1,941 4,257 6,316 7,572 8,742
430,000 440,000 1,994 4,374 6,490 7,781 8,983
440,000 450,000 2,047 4,491 6,664 7,990 9,223
450,000 460,000 2,101 4,608 6,838 8,198 9,464
460,000 470,000 2,154 4,726 7,011 8,407 9,705
470,000 480,000 2,208 4,843 7,185 8,615 9,946
480,000 490,000 2,261 4,960 7,359 8,824 10,186
490,000 500,000 2,314 5,077 7,533 9,033 10,427
500,000 and over 2,368 5,194 7,707 9,241 10,668

SECTION 5. EFFECTIVE DATE
This revenue procedure applies to passenger automobiles placed in service during
calendar year 2026 or with a lease term beginning in calendar year 2026.
SECTION 6. DRAFTING INFORMATION
The principal authors of this notice are personnel from the Office of Associate Chief
Counsel (Income Tax and Accounting). For further information regarding this revenue
procedure, please contact the Office of the Associate Chief Counsel (Income Tax and
Accounting), Branch 7, at (202) 317-7005 (not a toll-free number).

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