us-irs-revenue-procedures-rp-25-16•rp-25-16.pdf
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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. 2025-16 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 2025; 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 2025. These tables reflect the automobile price inflation adjustments required by § 280F(d)(7) of the Internal Revenue Code. 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 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 - 2 - All Urban Consumers published by the Department of Labor (C-CPI-U). .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 the applicable percentage of the property’s adjusted basis, referred to as “§ 168(k) additional first year depreciation deduction” hereinafter. Pursuant to § 168(k)(6)(A), the applicable percentage is 100 percent for qualified property acquired and placed in service after September 27, 2017, and placed in service before January 1, 2023, and is phased down 20 percent each year for property placed in service through December 31, 2026. Accordingly, the applicable percentage for qualified property acquired after September 27, 2017, and placed in service after December 31, 2024, and before January 1, 2026, is 40 percent. Pursuant to § 168(k)(8)(D)(i), no § 168(k) additional first year depreciation deduction is allowed or allowable for qualified property acquired by the taxpayer before September 28, 2017, and placed in service by the taxpayer after 2019. For qualified property acquired and placed in service after September 27, 2017, § 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 2025. 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 2025, for which the § 168(k) additional first year depreciation deduction applies. Table 2 provides depreciation limitations for passenger automobiles placed in service by the taxpayer during calendar year 2025 for which no § 168(k) additional first - 3 - year depreciation deduction applies. The § 168(k) additional first year depreciation deduction does not apply for 2025 if the taxpayer: (1) did not use the passenger automobile during 2025 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 the passenger automobile used and the acquisition of such property did not meet the acquisition requirements in § 168(k)(2)(E)(ii) and § 1.168(k)-2(b)(3)(iii) of the Income Tax Regulations; or (4) acquired the passenger automobile before September 28, 2017, and placed it in service after 2019. .04 Section 280F(c)(2) requires a reduction to the amount allowable as a deduction 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 2025 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 2025 and - 4 - 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 2025 and continue to apply for each taxable year during the lease. .03 For other recent calendar years, see Rev. Proc. 2020-37, 2020-33 I.R.B. 381, for passenger automobiles placed in service or leased during calendar year 2020; 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; and Rev. Proc. 2024-13, 2024-9 I.R.B. 678, for passenger automobiles placed in service or leased during calendar year 2024. 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 - 5 - 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 November 2024 was 123.153 for October 2024. The October 2024 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 22.561 (123.153 - 100.592). The percentage by which the C-CPI- U new vehicle component for October 2024 exceeds the product of the new vehicle component of the CPI for October of 2017 and the amount determined under § 1(f)(3)(B) is 22.428 percent (22.561/100.592 x 100%), the automobile price inflation adjustment for 2025 for passenger automobiles. The dollar limitations in § 280F(a) are therefore multiplied by a factor of 0.22428, 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 2025. This adjustment applies to all passenger automobiles that are placed in service in calendar year 2025. (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 2025. 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 2025; use Table 2 for a passenger automobile for which no § 168(k) - 6 - additional first year depreciation deduction applies. REV. PROC. 2025-16 TABLE 1 DEPRECIATION LIMITATIONS FOR PASSENGER AUTOMOBILES ACQUIRED AFTER SEPTEMBER 27, 2017, AND PLACED IN SERVICE DURING CALENDAR YEAR 2025, FOR WHICH THE § 168(k) ADDITIONAL FIRST YEAR DEPRECIATION DEDUCTION APPLIES Tax Year Amount 1st Tax Year $ 20,200 2nd Tax Year $ 19,600 3rd Tax Year $ 11,800 Each Succeeding Year $ 7,060 REV. PROC. 2025-16 TABLE 2 DEPRECIATION LIMITATIONS FOR PASSENGER AUTOMOBILES PLACED IN SERVICE DURING CALENDAR YEAR 2025 FOR WHICH NO § 168(k) ADDITIONAL FIRST YEAR DEPRECIATION DEDUCTION APPLIES Tax Year Amount 1st Tax Year $ 12,200 2nd Tax Year $ 19,600 3rd Tax Year $ 11,800 Each Succeeding Year $ 7,060 .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 2025. In applying these procedures, lessees of passenger automobiles should use Table 3 of this revenue procedure. - 7 - REV. PROC. 2025-16 TABLE 3 DOLLAR AMOUNTS FOR PASSENGER AUTOMOBILES WITH A LEASE TERM BEGINNING IN CALENDAR YEAR 2025 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 13 26 36 43 50 64,000 66,000 25 53 78 92 107 66,000 68,000 38 81 118 142 163 68,000 70,000 50 109 159 191 220 70,000 72,000 63 136 201 240 277 72,000 74,000 76 164 241 289 334 74,000 76,000 88 192 282 338 391 76,000 78,000 101 219 324 387 447 78,000 80,000 113 247 364 437 504 80,000 85,000 135 295 437 522 604 85,000 90,000 167 364 539 646 745 90,000 95,000 198 434 641 768 888 95,000 100,000 230 502 744 892 1,029 100,000 110,000 277 606 898 1,076 1,242 110,000 120,000 340 744 1,103 1,322 1,525 120,000 130,000 403 882 1,308 1,568 1,809 130,000 140,000 466 1,021 1,512 1,814 2,093 140,000 150,000 529 1,159 1,717 2,060 2,377 150,000 160,000 592 1,297 1,923 2,305 2,661 160,000 170,000 655 1,435 2,128 2,551 2,945 170,000 180,000 718 1,573 2,333 2,797 3,229 180,000 190,000 781 1,711 2,538 3,043 3,513 190,000 200,000 844 1,850 2,742 3,289 3,797 200,000 210,000 907 1,988 2,948 3,534 4,081 210,000 220,000 970 2,126 3,153 3,780 4,364 220,000 230,000 1,033 2,264 3,358 4,026 4,648 230,000 240,000 1,096 2,402 3,563 4,272 4,932 240,000 and over 1,159 2,540 3,768 4,518 5,216 - 8 - SECTION 5. EFFECTIVE DATE This revenue procedure applies to passenger automobiles placed in service during calendar year 2025 or with a lease term beginning in calendar year 2025. SECTION 6. DRAFTING INFORMATION The principal author of this revenue procedure is Knolan Smith of the Office of Associate Chief Counsel (Income Tax & Accounting). For further information regarding this revenue procedure, contact Mr. Smith at (202) 317-7005 (not a toll-free number).
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