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Tax deductions, credits, and amortization

What is the class life for qualified improvement property under Section 179(d)(5)(B) in a commercial office building?

Last updated: 
Sep 2025
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Answer

The class life for qualified improvement property (QIP) in a commercial office building, as relevant for Section 179(d)(5)(B), is determined by reference to the definition and treatment of QIP under the Internal Revenue Code and related guidance.

1. Definition and Recovery Periods

- Qualified improvement property is defined as any improvement made by the taxpayer to an interior portion of a building which is nonresidential real property, provided the improvement is placed in service after the date the building was first placed in service. QIP does not include improvements attributable to the enlargement of the building, any elevator or escalator, or the internal structural framework of the building.

2. Class Life

- The class life for QIP is not directly stated in Section 179(d)(5)(B), but is determined by reference to the class life tables and the statutory assignment under Section 168.

- Under Section 168(e)(3)(E)(vii), as amended by the CARES Act, QIP is assigned a 15-year recovery period for the General Depreciation System (GDS) and a 20-year recovery period for the Alternative Depreciation System (ADS).

- The class life for QIP is therefore 15 years for GDS and 20 years for ADS.

3. Supporting Guidance

- IRS Publication 946 and the MACRS Depreciation Guide confirm that QIP placed in service after 2017 is 15-year property under GDS and 20-year property under ADS.

- The IRS Cost Segregation Audit Technique Guide also confirms that QIP is assigned a 15-year recovery period for GDS and 20 years for ADS, and that the class life is 15 years for GDS.

4. Summary Table Reference

- In the MACRS tables, QIP is listed as 15-year property with a 15-year class life for GDS and a 20-year recovery period for ADS.

5. Conclusion

For qualified improvement property in a commercial office building, the class life is 15 years under the General Depreciation System (GDS) and 20 years under the Alternative Depreciation System (ADS).

This 15-year class life is the relevant period for Section 179(d)(5)(B) purposes for QIP in a commercial office building.

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