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1245X Study – Minimizing Depreciation Recapture at Property Sale

We are aware that owners face an unexpected tax burden when selling a commercial or investment property: depreciation recapture. A 1245X study, also called a reverse cost segregation study (CSS), is a custom-specialized tax strategy performed at the time of sale. Its goal is to assign fair market value (FMV) to Section 1245 assets, generally at amounts lower than when they were originally placed in service. This approach can lower or even eliminate depreciation recapture. It simply converts the temporary benefits of a traditional cost segregation study into permanent tax savings.

Unlike traditional cost segregation studies performed during ownership, a 1245X study is completed at the time of sale, providing tax savings at closing instead of temporary deferrals during ownership.

What Is a 1245X Study?

A 1245X study is simply a focused tax analysis that assigns FMV to Section 1245 assets at the moment of sale.

  • It occurs only when a property is sold, not during its ownership
  • The study’s primary purpose is to accurately determine the FMV of Section 1245 assets using IRS-accepted valuation methods. It might result in lower depreciation recapture liability if the FMV supports it
  • By doing so, it presents tax savings at the time of sale. It aids property owners and investors exit an investment on stronger financial footing

Think of it as the reverse of a standard cost segregation study. Instead of accelerating depreciation deductions early in ownership, a reverse CSS study reallocates asset values at the end, which would have a minimizing influence on tax exposure when selling the property.

How the Process Works

A 1245X study, or reverse cost segregation study, is carried out at the time of a property sale to strategically reassign asset values and reduce depreciation recapture. The process is well-structured and fully compliant with IRS standards to establish full precision as well as defensible results:

Data Collection

  • Gather historical property records
  • Review past depreciation schedules
  • Compile purchase and sale agreements

Fair Market Value Determination

  • Locate all Section 1245 assets covered in the property sale
  • Leverage accepted valuation methods in order to assess current FMV for audit-ready accuracy

 

Reallocate Asset Values

  • Assign FMV to Section 1245 assets based on objective and defensible valuation approaches like cost or market and income methods
  • Establish a clear and supportable allocation for tax reporting

Reduce or Eliminate Depreciation Recapture

  • When the FMV of Section 1245 assets is established below the original placed-in-service amounts, depreciation recapture liability is majorly reduced or, in some cases, completely eliminated.
  • This outcome creates permanent tax savings rather than temporary deferrals, but the exact result depends on accurate valuations and the taxpayer’s circumstances..

Prepare Audit-Ready Documentation

  • Deliver comprehensive reports in order to support tax filings and protection against IRS challenges
  • Make sure that every value assigned is defensible and well-documented

Understanding Section 1245 Assets

The IRS defines Section 1245 property as specific types of depreciable personal property that are generally part of a commercial or investment property sale. Such assets include in general:

  • machinery and equipment
  • specialized fixtures
  • specific removable fixtures or specialty items not considered structural components

Because Section 1245 assets depreciate at a faster rate than the building’s structure, they are naturally subject to higher depreciation recapture taxes at the time of sale. This makes them the primary focus of a reverse CSS. 

By accurately establishing FMV for such assets during the study, property owners are able to significantly reduce or eliminate depreciation recapture.

1245X Study Matters

By focusing on Section 1245 assets, reverse cost segregation study process presents assistance to property owners in preventing costly taxation surprises and achieving lasting savings. Advantages of 1245X Study can be outlined as follows:

  • Reduced or fully eliminated depreciation recapture tax by strategically assigning lower FMV to Section 1245 assets
  • Tax savings at the time of sale by shifting gain from ordinary income (Section 1245 recapture) to unrecaptured Section 1250 gain or capital gain rates, which are lower in general.
  • Defensible FMV assignments for tax reporting accuracy
  • Lower audit risk thanks to professional and detailed documentation that aligns with IRS standards
  • Simplified exit planning when selling commercial or investment properties which allows a smoother transition

A well-executed 1245X study gives property owners confidence along with clarity. It also makes sure that they keep more of their proceeds when exiting an investment.

Cost Segregation vs. 1245X Studies

It is true that both cost segregation and 1245X studies analyze asset values. Yet, their timing, goals, and results are very different.

  • Traditional cost segregation is performed during ownership to accelerate depreciation and boosts short-term cash flow by front-loading deductions.
  • A 1245X study, also known as a reverse cost segregation study, works in the opposite way. It is completed at the time of sale to reallocate values of Section 1245 assets and accurately documents FMV to potentially reduce depreciation recapture, in parallel to the actual valuation results.
FeatureCost Segregation Study1245X Study (Reverse CSS)
TimingDuring ownership (construction, acquisition, or renovation)At the time of property sale
GoalAccelerate depreciation for short-term cash flowStrategically assign lower FMV to Section 1245 assets to minimize or eliminate depreciation recapture and make prior tax deferrals permanent
OutcomeTemporary tax deferralTax savings at the time of sale through defensible FMV allocations
ScopeEntire building componentsFocus on Section 1245 components while also documenting allocations among land, Section 1250 building, and Section 1245 property


In short:

  • Cost segregation boosts cash flow while you own the property.
  • A 1245X study makes sure that  you keep more of your proceeds when you sell.

Who Should Consider a 1245X Study

This strategy is ideal for the groups as presented below:

  • Commercial property owners preparing to sell
  • Investors seeking to minimize taxes on a portfolio exit
  • Real estate partnerships or LLCs planning for a transfer or buyout
  • Businesses with significant equipment or specific non-structural leasehold items covered in the sale
  • Partial dispositions during renovations, where specific components are replaced or retired.

Plan Ahead for Permanent Savings

It should be realized that selling a property without a 1245X study generally results in unnecessary tax costs due to depreciation recapture. By planning ahead, it is completely possible to reduce such liability and increase your net proceeds at closing.

Results depend on actual FMVs and IRS reporting requirements. It is true that the results vary in line with the valuations and IRS reporting. Yet, a reverse CSS offers a defensible, IRS-compliant strategy that generally reduces or fully eliminates depreciation recapture.

At Dimov Tax, our dedicated team presents comprehensive 1245X study services, including valuation and documentation as well as IRS-compliant reporting. Our experts focus on Section 1245 assets to structure the sale in a way that achieves maximum savings and establishes full compliance with regulations. Contact Dimov Tax to learn how a 1245X study can help you minimize depreciation recapture and secure major tax savings at the time of sale.

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