Ricerca

Cost segregation for manufacturers

In short

A plant is full of building cost that exists for the machines: foundations, dedicated power, process piping, compressed air, process cooling. A study traces it to shorter recovery periods. For new construction that began after January 19, 2025, the production portion of the building may also qualify for the new §168(n) 100% election. And because many manufacturers claim the R&D credit, the two studies can be run on the same facts without overlapping.

Manufacturing at a glance

Building life
39 years
Reported reclassification
15% to 28%
New plants
§168(n) election
Pairs with
R&D credit, §174A

Range is competitor-reported for industrial and warehouse property, not a promise for any plant.

What a study looks at in a plant

The dividing line is function: does it serve the production process or the building?

Manufacturing components a study analyzes
Component How it is analyzed
Equipment foundations, pits and supportsBuilt for specific machinery rather than the building; analyzed with the equipment they carry.
Process electrical: dedicated feeders, panels, bus duct to machinesAllocated by what the circuits serve. General lighting and building power stay structural.
Process piping, compressed air, process water and exhaustSystems that serve production equipment, separated from building plumbing and HVAC.
HVAC for clean rooms or process temperature and humidityMoves out of the building only when its sole justification is the process or equipment; comfort conditioning stays.
Paving, truck courts, rail spurs, fencing, site lightingLand improvements, generally 15-year.
The production portion of a new buildingPossibly qualified production property under §168(n): an elective 100% deduction for qualifying new construction.
General principles, not conclusions for any facility.

Qualified production property: §168(n)

P.L. 119-21 added an elective 100% deduction for the part of a new nonresidential building used in manufacturing, production or refining. The IRS issued interim guidance in Notice 2026-16. Broadly, construction has to begin after January 19, 2025 and before January 1, 2029, the property has to be placed in service after July 4, 2025 and before 2031, and its original use has to begin with you.

The election covers only the production portion, so someone has to separate the production floor from offices, research space and storage. That is the same component-level analysis a cost segregation study does. A change in use within ten years can trigger recapture, so the study also documents how each area is used.

Pairing it with the R&D credit

Process engineering, tooling development and first-article runs are often qualified research under IRC §41. The building and the equipment are not: depreciable property is excluded from qualified supplies, and its cost is not a §174 research expenditure. Run on the same facts, the two studies capture both benefits without either touching the other’s costs.

See the R&D credit for manufacturers, §174A expensing, and both studies on one facility.

State tax, again

Many manufacturing states do not follow federal bonus depreciation. Pennsylvania, for example, requires an add-back for corporate net income tax purposes. The study’s asset schedule carries the class and placed-in-service detail your preparer needs to keep the state schedule.

Questions manufacturers ask

Can the same cost count for the R&D credit and the building study?
No, and a well-run engagement keeps them apart. Depreciable property is never a qualified research supply under §41(b)(2)(C), and the cost of depreciable property is not a §174 research expenditure. What the R&D study covers is wages, consumed supplies and contract research; the building study covers the building.
Is §168(n) qualified production property available for an existing plant?
Generally not. It requires original use and construction beginning after January 19, 2025 and before 2029, with the property placed in service after July 4, 2025. For an existing plant, a regular cost segregation study (and a look-back if you have owned it a while) is the route.
We expanded the plant last year. Is that a study on its own?
It can be. An addition or a major renovation has its own placed-in-service date and usually the best cost records you will ever have. It is often worth studying even when the original building is not.

Primary sources

What this page relies on, as reviewed October 2, 2026.

Tax law, IRS guidance and state conformity change. Confirm the current rules and how they apply to your property with a qualified professional before acting.

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