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Tax deductions, credits, and amortization

How does IRS Section 179 affect self-employed taxpayers compared to corporations?

Last updated: 
Sep 2025
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Answer

IRS Section 179 allows taxpayers to elect to expense the cost of qualifying property in the year it is placed in service, rather than recovering the cost through depreciation over several years. The rules for Section 179 apply to both self-employed individuals (sole proprietors, single-member LLCs, and partners in partnerships) and corporations (including S corporations and C corporations), but there are important similarities and differences in how the deduction is applied and limited for each type of taxpayer.

1. Eligibility and Qualifying Property

Self-Employed Taxpayers:- Eligible to claim Section 179 for property acquired by purchase for use in the active conduct of a trade or business.- Qualifying property includes tangible personal property, certain improvements to nonresidential real property (qualified improvement property, roofs, HVAC, fire protection, and security systems), off-the-shelf computer software, and certain other property used in business.- Property must be used more than 50% for business in the year placed in service.- Property acquired by gift or inheritance, or from related parties, does not qualify.

Corporations:- Corporations (C and S) are also eligible to claim Section 179 for qualifying property used in their trade or business.- The same types of property qualify as for individuals.- Estates and trusts are not eligible for Section 179.

2. Dollar Limits and Phase-Out

For 2025 (as adjusted by recent law):- Maximum Section 179 deduction: $2,500,000.- Phase-out threshold: $4,000,000. The deduction is reduced dollar-for-dollar by the amount by which the cost of qualifying property placed in service exceeds $4,000,000.

Application:- These limits apply per taxpayer, not per business or per asset.- For married individuals filing separately, the limits must be allocated between spouses unless they elect otherwise.- For corporations, the limits apply at the entity level.

Controlled Groups:- All members of a controlled group (more than 50% common ownership) are treated as a single taxpayer for purposes of the Section 179 limits, and the deduction must be allocated among the group.

3. Business Income Limitation

Self-Employed Taxpayers:- The Section 179 deduction cannot exceed the taxpayer’s aggregate taxable income from the active conduct of any trade or business during the year.- Taxable income for this purpose includes wages, salaries, tips, and other earned income, as well as net income from sole proprietorships, partnerships, and S corporations.- If the deduction is limited by business income, the excess can be carried forward to future years.

Corporations:- The deduction is limited to the corporation’s taxable income from the active conduct of any trade or business.- For S corporations and partnerships, the limitation applies at both the entity and shareholder/partner level. The entity computes the allowable deduction, which is then allocated to shareholders/partners, who must also apply the business income limitation at their level.

4. Special Rules for Partnerships and S Corporations

  • The Section 179 deduction is computed at the entity level and then allocated to the partners or shareholders.
  • Each partner or shareholder adds their share of the entity’s Section 179 deduction to their own Section 179 property and applies the dollar and business income limitations at their level.
  • Estates and trusts cannot claim Section 179, nor can partners or shareholders that are themselves estates or trusts.

5. Noncorporate Lessors

  • Noncorporate lessors (including self-employed individuals) generally cannot claim Section 179 for property they lease to others, unless:
  • The property was manufactured or produced by the lessor, or
  • The lease term is less than 50% of the class life of the property, and for the first 12 months, the lessor’s Section 162 deductions (other than rent and reimbursed amounts) exceed 15% of the rental income.
  • This restriction does not apply to corporations.

6. Recapture Rules

  • If, in any year during the property’s recovery period, business use drops to 50% or less, a portion of the Section 179 deduction must be recaptured as ordinary income.

7. Interaction with Bonus Depreciation

  • Section 179 expensing is applied before bonus depreciation and regular MACRS depreciation.
  • Both self-employed taxpayers and corporations may use Section 179 and bonus depreciation in the same year, subject to their respective limitations.

8. Reporting and Elections

Self-Employed:- The election is made on Form 4562, attached to the taxpayer’s return (e.g., Schedule C for sole proprietors).

Corporations:- The election is made on Form 4562, attached to Form 1120 (C corporations) or Form 1120-S (S corporations).

9. Key Differences Summarized

FeatureSelf-Employed (Individuals)Corporations (C & S)
Dollar/Phase-Out LimitsApply per taxpayerApply per entity
Business Income LimitationIncludes wages, self-employmentBased on entity’s taxable income
Controlled Group RulesN/A (unless multiple businesses)Must aggregate for >50% ownership
Noncorporate Lessor LimitationAppliesDoes not apply
Estates/TrustsNot eligibleNot eligible
Partnerships/S CorpsDeduction at entity and owner levelDeduction at entity and owner level
RecaptureApplies if business use dropsApplies if business use drops

10. Practical Planning Considerations

  • Section 179 cannot create a net loss; bonus depreciation can. This is a key distinction: self-employed taxpayers and corporations cannot use Section 179 to reduce taxable income below zero, but can carry forward any unused amount.
  • Section 179 provides flexibility to select which assets to expense, while bonus depreciation must be applied to all assets in a class unless the taxpayer elects out for a class of property.
  • For S corporations and partnerships, the Section 179 deduction is limited at both the entity and owner level, and cannot be claimed by shareholders or partners that are estates or trusts.

Summary: Section 179 provides a valuable opportunity for both self-employed taxpayers and corporations to accelerate deductions for qualifying property. The main differences are in the application of the business income limitation, the treatment of controlled groups, and the noncorporate lessor rule. Both types of taxpayers must be mindful of the annual dollar and phase-out limits, the business income limitation, and the recapture rules. For S corporations and partnerships, the deduction is subject to limitations at both the entity and owner level, and cannot be claimed by estates or trusts. Section 179 cannot create a net loss, but any unused deduction can be carried forward. Bonus depreciation, by contrast, is not subject to a business income limitation and can create a net loss.

For detailed planning, taxpayers should consider their current and projected business income, the composition of their business entities, and the nature of their asset acquisitions to maximize the benefit of Section 179 and bonus depreciation.

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