Cost Segregation, Bonus Depreciation, and the One Big Beautiful Bill Act

A cost segregation study is an engineering-based analysis that separates the cost of a building into its component assets and assigns each component its correct depreciation recovery period, so that items properly classified as tangible personal property or land improvements are depreciated over 5, 7 or 15 years instead of the 39 years that applies to a nonresidential building. Florida owners are asking about it again because of Public Law 119-21, enacted July 4, 2025 and commonly known as the One Big Beautiful Bill Act, which amended Internal Revenue Code Section 168(k) to restore a 100 percent first-year bonus depreciation allowance for qualifying property acquired after January 19, 2025. This page sets out the mechanism, the statutory conditions attached to it, and the three places it most often goes wrong: depreciation recapture, the passive-loss and excess-business-loss limits, and the interaction with a Section 1031 exchange.

What is a cost segregation study, and who performs it?

A cost segregation study is an engineering-based analysis that breaks a building’s purchase or construction cost into individual assets and assigns each one the recovery period the tax law actually gives it. The IRS Cost Segregation Audit Technique Guide (Publication 5653, revised February 6, 2025) describes the exercise as what happens when only lump-sum costs are available and cost-estimating techniques are needed to segregate or allocate costs to individual items of property such as land, land improvements, buildings, equipment, furniture and fixtures.

The distinction that drives the whole analysis is statutory. A building is Section 1250 property: generally nonresidential real property with a 39-year recovery period, or residential rental property at 27.5 years, and it must use straight-line depreciation. Equipment, furniture and fixtures are Section 1245 property — tangible personal property with a shorter recovery period, commonly 5 or 7 years, which can also be eligible for accelerated depreciation. Section 1245(a)(3) specifically excludes a building and its structural components from the definition of Section 1245 property, which is why the classification work has to be done asset by asset rather than assumed. Recovery periods are not a matter of opinion: the audit guide notes that General Depreciation System recovery periods are 3, 5, 7, 10, 15, 20, 25, 27.5, 39 or 50 years, and that Revenue Procedure 87-56 sets the class lives used to compute depreciation under Section 168.

Who performs a study — and what the IRS says about that

Cost segregation studies are performed by specialist engineering and accounting firms. They are not performed by real estate brokers, and Ironmark does not perform them. The IRS audit guide is unusually direct on qualifications: it states that there are no prescribed qualifications for cost segregation preparers, that the IRS has not established any requirements or standards for the preparation of these studies, and that a preparer’s credentials and level of expertise may bear on the overall accuracy and quality of a study. It adds that in general a study by a construction engineer is more reliable than one conducted by someone with no engineering or construction background, while noting that cost-estimating and allocation experience and knowledge of the applicable tax law are also important criteria, and that a quality study identifies the preparer and references their credentials and experience.

The same guide lists thirteen principal elements of a quality study — among them a documented methodology, an engineering take-off with unit costs, an explanation of the legal analysis, and reconciliation of total allocated costs to total actual costs — which is a fair description of what the client is buying. One caveat belongs with every citation to that document: it carries its own disclaimer that it is not an official pronouncement of the law or the position of the Service and cannot be used, cited or relied upon as such. It is best read as a description of how IRS examiners approach these studies.

How does a cost segregation study reclassify a building’s cost?

A study moves cost out of the 39-year line and into shorter-lived categories where the components genuinely belong under Section 1245 and the MACRS class lives. The table below shows the categories and the recovery periods, using the kinds of assets the IRS audit guide itself discusses. Only the shorter-lived categories sit inside the 20-year ceiling that Section 168(k)(2)(A)(i)(I) puts on bonus-eligible property, which is precisely why cost segregation and bonus depreciation are discussed together.

Categories and recovery periods per IRC §§ 1245, 1250 and 168, Rev. Proc. 87-56, and IRS Publication 5653, Cost Segregation Audit Technique Guide (rev. 2-6-2025). Classification of any specific asset is a facts-and-circumstances determination for the study preparer and the taxpayer’s CPA.

The hard part is not the obvious assets; it is the shared ones. The audit guide gives the example of a building’s electrical system, portions of which support both Section 1245 property and Section 1250 property, and notes that a study will typically identify the costs of the branch circuits feeding the Section 1245 property. Allocation inside a single building system is where studies are challenged on examination.

What did the One Big Beautiful Bill Act do to bonus depreciation?

Public Law 119-21, enacted July 4, 2025, amended Internal Revenue Code Section 168(k) to set the additional first-year depreciation allowance at 100 percent, and repealed the statutory phase-down. Section 70301(b) of the Act struck the words “the applicable percentage” from Section 168(k)(1)(A) and inserted “100 percent,” and repealed Section 168(k)(6) — the paragraph that contained the declining schedule — along with Section 168(k)(8). The IRS refers to the statute in its own guidance as Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act.

The date that controls is the acquisition date, not the placed-in-service date

This is the single most misread point in the new rules. Section 70301(c)(1) of the Act provides that the amendments apply to property acquired after January 19, 2025. Section 70301(c)(4) then adds an acquisition-date rule: property is not treated as acquired after the date on which a written binding contract is entered into for its acquisition. A building or asset under a written binding contract on or before January 19, 2025 therefore carries that earlier acquisition date, and does not reach the 100 percent rate, even if it is placed in service much later. A buyer who signed in December 2024 and closed in 2025 is in a materially different position from a buyer who signed in February 2025, and only the CPA reviewing the contract can say which one applies.

The conditions a half-told version of this rule leaves out

• A 20-year ceiling. Section 168(k)(2)(A)(i)(I) limits qualified property to property with a recovery period of 20 years or less. A 39-year building shell is not bonus-eligible — which is the entire reason cost segregation is relevant to bonus depreciation.
• Used property can qualify. Section 168(k)(2)(E)(i) permits used property, provided the property was not used by the taxpayer at any time before acquisition and the acquisition satisfies the related-party, carryover-basis and controlled-group conditions cross-referenced from Section 179(d). This is the provision that makes bonus depreciation relevant to the buyer of an existing Florida industrial building rather than only to new construction.
• Property on the alternative depreciation system is excluded. Section 168(k)(2)(D) provides that qualified property does not include property to which the alternative depreciation system applies.
• A taxpayer can elect out. Section 168(k)(7) permits an election out of bonus depreciation, made by class of property for a taxable year, revocable only with the consent of the Secretary.
• There is a transitional election to take 40 percent instead. Section 70301(b)(3) of the Act added Section 168(k)(10)(A), under which a taxpayer may elect, for the first taxable year ending after January 19, 2025, to substitute 40 percent for 100 percent (60 percent for certain categories of property). An election to take a smaller deduction exists because a full first-year deduction is not always the better outcome. Whether it is worth making is a question for the CPA, not for a broker.
• The guidance is interim. IRS Notice 2026-11 provides interim guidance on the amended Section 168(k) and states that Treasury and the IRS intend to issue proposed regulations. Taxpayers may rely on stated sections of the Notice for property placed in service in taxable years beginning before those proposed regulations are published, provided they follow the guidance in its entirety for all eligible property placed in service in such years.

How is Section 179 different from bonus depreciation?

Section 179 expensing and bonus depreciation both produce a first-year write-off, but they are not interchangeable and they do not use the same effective-date test. Section 70306 of Public Law 119-21 raised the Section 179 dollar limitation from $1,000,000 to $2,500,000 and the phase-out threshold from $2,500,000 to $4,000,000, effective for property placed in service in taxable years beginning after December 31, 2024. Bonus depreciation, by contrast, keys off property acquired after January 19, 2025. Those are two different tests and should not be blurred together.

For an owner-user of an existing Florida industrial building, that last row is the useful one. A new roof or a new rooftop HVAC unit on a building already in service is 39-year property. It cannot take bonus depreciation, because it fails the 20-year test. It can be expensed under Section 179 as qualified real property — subject to the dollar cap, the phase-out, and the business-income limit, all three of which have to be tested against the taxpayer’s actual return.

What is qualified improvement property, and did the Act change it?

Public Law 119-21 made no amendment to qualified improvement property. The phrase does not appear anywhere in the enacted text of the Act, and neither does Section 168(e)(6), the provision that defines it. QIP nonetheless reaches the 100 percent rate, but indirectly and for a reason that predates the Act.

Qualified improvement property is defined by the IRS as any improvement to an interior portion of a nonresidential building placed in service after the date the building was first placed in service, excluding any improvement attributable to the enlargement of the building, any elevator or escalator, and the internal structural framework of the building; the definition also limits QIP to improvements made by the taxpayer. As originally enacted in 2017 it carried a 39-year recovery period and so was not bonus-eligible. The Coronavirus Aid, Relief, and Economic Security Act (Public Law 116-136) retroactively changed that recovery period to 15 years under the General Depreciation System and 20 years under the alternative depreciation system, which is what brought QIP inside the class of property eligible for bonus depreciation.

The accurate way to state it is therefore this: QIP carries a 15-year recovery period as a result of the 2020 CARES Act amendment, which places it within the 20-year class that Section 168(k)(2)(A)(i)(I) makes eligible for the 100 percent first-year deduction restored by Public Law 119-21. The Act did not need to mention QIP to change its outcome, and it did not mention it.

Does the new 100 percent expensing for production property apply to a Florida industrial building?

For most Florida industrial owners the answer is no, and the reasons are worth stating before the headline. Section 70307 of Public Law 119-21 added a new Internal Revenue Code Section 168(n), which allows an election to expense 100 percent of the adjusted basis of qualified production property — nonresidential real property, meaning the building shell itself. It is the only place in current law where a building shell can be fully expensed. The conditions are narrow:

• Lessors are excluded outright. Section 168(n)(2)(A) provides that where the taxpayer is a lessor, property used by a lessee is not treated as used by the taxpayer as part of a qualified production activity. A net-lease investor cannot use Section 168(n); only an owner-occupier conducting the production activity can.
• “Production” is defined narrowly. Section 168(n)(2)(E) provides that the term production does not include activities other than agricultural production and chemical production, so the qualifying activities are manufacturing, agricultural production, chemical production and refining — not distribution, not warehousing, not general industrial or service use. Section 168(n)(2)(D) adds that activities do not constitute manufacturing, production or refining unless they result in a substantial transformation of the property comprising the product.
• Office and support space is carved out. Section 168(n)(2)(C) excludes portions used for offices, administrative services, lodging, parking, sales activities, research activities, software development or engineering activities, or other functions unrelated to the manufacturing, production or refining of tangible personal property.
• The windows are fixed, and the election is close to permanent. Construction must begin after January 19, 2025 and before January 1, 2029; the property must be placed in service before January 1, 2031; original use must commence with the taxpayer, subject to a used-property exception; and under Section 168(n)(6)(B) the election may not be revoked except with the consent of the Secretary, given only in extraordinary circumstances.
• There is a ten-year recapture. Section 168(n)(5) provides that if within 10 years of being placed in service the property ceases to be used in the qualified production activity and is used in another productive use, Section 1245 applies as if the property were disposed of at that time. Section 70307(b) of the Act amended Section 1245(a)(3) to make qualified production property Section 1245 property.

Most Florida industrial owner-users are distribution, contractor, service or light-assembly operations rather than manufacturers producing a substantially transformed product. Whether a given operation meets the manufacturing, agricultural production, chemical production or refining test is a facts-and-circumstances determination for the taxpayer’s CPA, and this page takes no position on any particular building.

How do cost segregation and a 1031 exchange interact?

They interact in several distinct ways. One of those interactions works in the owner’s favor and the rest are limits — which is why the exchange structure and the depreciation plan belong in the same model, built before the relinquished property closes rather than one after the other. This is the part owner-users most often get wrong.

First: the Act did not change Section 1031

Public Law 119-21 made no amendment to Internal Revenue Code Section 1031. The terms like-kind, qualified intermediary and deferred exchange do not appear in the enacted text of the Act. Section 1031(a)(1) continues to provide that no gain or loss is recognized on the exchange of real property held for productive use in a trade or business or for investment if it is exchanged solely for real property of like kind to be held for productive use in a trade or business or for investment; Section 1031(a)(3) continues to require identification of replacement property within 45 days and receipt within the earlier of 180 days or the due date of the return for the year of transfer; and Section 1031(b) continues to recognize gain to the extent of money and other property received. The limitation of Section 1031 to real property is older than the Act and comes from the Tax Cuts and Jobs Act of 2017. Ironmark’s 1031 exchange advisory page covers the exchange mechanics in more detail.

Second: a Section 1245 classification does not push an asset out of the exchange

The common assumption is that if a cost segregation study reclassified part of a building as personal property, those components fall out of the like-kind exchange. That is backwards. Treasury Regulation Section 1.1031(a)-3(a)(7), promulgated by TD 9935 in December 2020, states that the definition of real property in that regulation applies only for purposes of Section 1031, that no inference is intended for other purposes of the Code such as depreciation and Sections 1245 and 1250, and gives the example that a structure or portion of a structure may be Section 1245 property for depreciation purposes notwithstanding that it is real property under the Section 1031 regulation. The same asset carries two independent classifications: one for depreciation, one for exchange eligibility, the latter turning in part on state or local law where the property sits.

Third: recapture can still be triggered inside a deferred exchange

The same regulation states that a taxpayer transferring relinquished property that is Section 1245 property in a Section 1031 exchange is subject to the gain recognition rules under Section 1245. Section 1245(b)(4) sets the limit: where gain is not recognized in whole or in part under Section 1031, the amount taken into account as ordinary income under Section 1245(a)(1) does not exceed the sum of the gain otherwise recognized on the disposition plus the fair market value of acquired property that is not Section 1245 property. Treasury Regulation Section 1.1245-4(d) implements that limit with worked examples. The practical consequence is that an owner who has cost-segregated a building heavily and then exchanges into replacement real estate with little Section 1245 content can find Section 1245 recapture triggered even though the exchange otherwise defers gain. The arithmetic is genuinely specific to the deal; this page states that the issue exists and stops there.

Fourth: on the replacement building, bonus depreciation may reach only the excess basis

Treasury Regulation Section 1.168(k)-2(g)(5)(iii)(A), promulgated by TD 9874, distinguishes two cases. Where replacement MACRS property meets the original use requirement, both the remaining exchanged basis and the remaining excess basis are eligible for the additional first year depreciation deduction. Where the replacement property instead meets the used property acquisition requirements, only the remaining excess basis is eligible. For the typical 1031 buyer acquiring an existing Florida industrial building, the excess basis is the new money invested above the basis carried over from the relinquished property. A cost segregation study on that replacement building can still be worth doing, but the bonus deduction is computed on a smaller base than for a buyer who purchased outside an exchange. Note also that IRS Notice 2026-11 does not address like-kind exchanges or this paragraph of the regulations, so the original-use versus used-property distinction is as far as published guidance currently goes.

And: the 15 percent incidental property rule is not a tax exemption

Treasury Regulation Section 1.1031(k)-1(g)(7)(iii) treats personal property as incidental to replacement real property where it is typically transferred together with the real property in standard commercial transactions and its aggregate fair market value does not exceed 15 percent of the aggregate fair market value of the replacement real property. That rule governs whether the taxpayer’s rights over funds held by a qualified intermediary are properly limited. It is a safe harbor for the exchange mechanics, not a deferral rule: the preamble to TD 9935 states expressly that incidental personal property is non-like-kind property that generally results in gain recognition under Section 1031(b). The frequently repeated claim that a taxpayer can take up to 15 percent in personal property tax-free in an exchange is not what the regulation says.

What happens on a later sale? Depreciation recapture, honestly stated

A cost segregation study does not eliminate tax. It changes the timing of deductions and, importantly, the character of the income that comes back on a later sale. That second effect is the one most often left out of the pitch.

Two corrections follow from that table. The first is that “depreciation recapture is taxed at 25 percent” conflates two different rules: the 25 percent figure is the maximum rate on unrecaptured section 1250 gain, while Section 1245 recapture is ordinary income, and a cost segregation study specifically increases the Section 1245 share. The second is that timing benefit and character cost run in opposite directions. A taxpayer who accelerates deductions in a low-bracket year and sells in a high-bracket year can end up worse off. Whether the timing benefit outweighs the character cost is a modeling question for the CPA, and it depends on the bracket, the entity, the holding period and the exit plan. This page states no rate, no saving and no outcome.

Can you run a study on a building you already own?

Yes — but not by amending old returns. The IRS audit guide states the long-standing position that a taxpayer adopts a permissible method of accounting in the tax year a depreciable asset is placed in service, and that a change in depreciation method, recovery period or convention resulting from a reclassification of that property is a change in method of accounting requiring the consent of the Commissioner, generally by filing Form 3115, Application for Change in Accounting Method, with the adjustment to taxable income made under Section 481(a). The guide states that a taxpayer who has adopted a method of accounting may not change it by amending prior income tax returns, citing Revenue Ruling 90-38, and that amended returns based on a cost segregation study performed after the original return was filed should generally be disallowed as an attempt to make a retroactive method change.

The practical version: an owner who has held a Florida industrial building for years can still commission a study and take the cumulative catch-up in the current year through Form 3115 and a Section 481(a) adjustment. The mechanism exists. Whether it produces a usable deduction in that year is a separate question governed by the limits described below.

Can a purchase agreement foreclose a cost segregation study?

It can, and this is the point most directly relevant to a broker’s job. In Peco Foods, Inc. v. Commissioner, T.C. Memo. 2012-018, affirmed at 522 F. App’x 840 (11th Cir. 2013), the taxpayer purchased two plants in applicable asset acquisitions and entered into written agreements with the seller allocating the purchase price among the acquired assets. It later commissioned a cost segregation study and filed Form 3115 to reclassify. The Tax Court held the taxpayer was bound by the clear and unambiguous terms of the original allocation schedules and could not deviate from that characterization, and so was not allowed to change its method of accounting under the study. The IRS audit guide, which discusses the case, adds that it is unclear whether the holding would apply to acquisitions other than applicable asset acquisitions under Section 1060.

The Eleventh Circuit covers Florida. The practical consequence for a Florida buyer is that the time to raise cost segregation with the CPA is before the purchase and sale agreement is signed, not after closing, because a binding allocation schedule inside the contract can foreclose the analysis later. That is a real reason to bring the tax advisors into an acquisition early, and it is one of the few points on this page where the brokerage sits genuinely upstream of the tax work. Ironmark raises it on buyer representation engagements; the allocation language itself is for the client’s CPA and attorney to draft.

When is a cost segregation study not worth doing?

A study is a professional engagement with a real cost, and there are several ordinary situations in which the deduction it produces cannot be used in the year it arrives. These are the honest downsides, each traceable to a statute or to IRS guidance.

Passive activity loss limits — Section 469

Public Law 119-21 did not amend Section 469. Under Section 469(a), passive activity losses are not allowed for individuals, estates, trusts, closely held C corporations and personal service corporations, and Section 469(c)(2) provides that the term passive activity includes any rental activity — rental is passive per se. The real estate professional exception in Section 469(c)(7) requires both that more than half of the taxpayer’s personal services in trades or businesses be performed in real property trades or businesses in which the taxpayer materially participates, and more than 750 hours of services in such businesses during the taxable year. Section 469(i) allows up to $25,000 of rental real estate loss with active participation, phased out by 50 cents per dollar of adjusted gross income above $100,000 and eliminated at $150,000. Section 469(g) generally frees suspended losses on a fully taxable disposition of the entire interest. For a retiring owner whose building has become a passive rental and who is not a real estate professional, a large accelerated deduction may be suspended rather than usable in the year it is generated.

Excess business loss limitation — Section 461(l)

Section 70601 of Public Law 119-21 made the excess business loss limitation permanent by striking its expiration date. For taxable years beginning in 2026, IRS Revenue Procedure 2025-32 sets the threshold at $256,000 ($512,000 for joint returns). Business losses above that threshold are disallowed for the year; Section 461(l)(2) provides that the disallowed amount is treated as a net operating loss carryover to subsequent years. The loss is deferred rather than lost, but a first-year deduction pushed into a later year is not the outcome the study was bought for.

Electing out of the interest limitation forces the alternative depreciation system

A real property trade or business may elect out of the Section 163(j) business interest limitation under Section 163(j)(7)(B), and that election is irrevocable. Section 168(g)(8) then requires the alternative depreciation system for nonresidential real property, residential rental property and qualified improvement property held by an electing real property trade or business, and Section 168(k)(2)(D) excludes ADS property from bonus depreciation. An electing real property trade or business therefore gives up bonus depreciation on its qualified improvement property. How that election interacts with shorter-lived personal property and land improvements is a question to put to the CPA rather than a conclusion to read off a web page.

The other cases worth raising with a CPA

• A building with a low depreciable basis, where there is little to reclassify in the first place.
• A building the owner intends to sell in the near term, where recapture arrives before much timing benefit has been earned.
• A taxpayer with no current income to absorb the deduction and no near-term prospect of it.
• A taxpayer already constrained by Section 469 or Section 461(l).
• Property acquired under an agreement containing a binding purchase-price allocation, per Peco Foods.
• A ground lease, leasehold or zero-cash-flow position, where there is little or no depreciable improvement basis for a study to work on.

Two further practical points. A study is real engineering work and carries a real fee; Ironmark does not publish a price range, because no primary source publishes one and every figure in circulation traces to a vendor’s own marketing — ask two or three qualified preparers directly. And aggressive studies are an examination subject: the IRS audit guide is, by design, a manual for examiners, and it cites Chief Counsel Advice 201805001 as an example of an engineer tax consultant held liable for the Section 6701 penalty for aiding and abetting an understatement of tax liability.

What is different about Florida?

Florida has no state personal income tax — Article VII, §5 of the Florida Constitution caps any such tax at the amount creditable against a similar federal tax, and because no such federal credit exists the practical ceiling is zero — so for an individual owner the deductions discussed on this page affect federal liability only. Florida does impose a corporate income tax, so an owner holding a building through a C corporation is in a different position, and that difference should not be generalized either way without the CPA looking at the entity.

Florida also imposes an ad valorem tax on tangible personal property. Florida Statutes Section 196.183 provides that each tangible personal property tax return is eligible for an exemption from ad valorem taxation of up to $25,000 of assessed value, and that the exemption does not apply in any year in which a taxpayer fails to timely file a return. The return, Form DR-405, is filed with the county property appraiser and is due April 1 according to the Florida Department of Revenue.

One question this page deliberately does not answer: Ironmark has not identified any Florida statute, Department of Revenue guidance, or county property appraiser guidance addressing whether a federal cost segregation reclassification bears on a county tangible personal property assessment. The federal and county systems use independent definitions, but that is not the same thing as an authority saying so, and a Florida CPA or ad valorem counsel should answer it for a specific property rather than a web page guessing.

What Ironmark does, and does not do

Ironmark Capital Advisory is a Florida commercial real estate brokerage specializing in industrial property, industrial outdoor storage and single-tenant net-lease investment. Ironmark does not perform cost segregation studies, does not prepare tax returns, and does not give tax or legal advice. Those services belong to specialist engineering firms, CPAs and attorneys the client engages directly, and the numbers they produce are theirs.

What an SIOR-designated advisory practice contributes to the same transaction is the real estate side of it:

• Valuation — a defensible read on what a Florida industrial building is worth before any tax planning is built on top of an assumed number.
• Investment sales and disposition — running a real process on the relinquished property, on a timeline that fits the exchange clock rather than fighting it.
• Buyer representation — sourcing and underwriting replacement property, and flagging the purchase-agreement allocation issue to the client’s advisors early enough to matter.
• 1031 exchange advisory — replacement-property identification inside the 45-day window, working alongside the client’s qualified intermediary.
• Net-lease investment — single-tenant net-lease assets for owners converting operating equity into passive income, with the depreciable-improvement question raised before the asset is chosen.
• Industrial outdoor storage — low-coverage yard and IOS assets, where the improvement mix is materially different from a conventional warehouse.

Market context behind the recommendations comes from Ironmark’s own research, published quarterly at Insights.

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Ironmark Capital Advisory represents owners, occupiers and investors across Florida’s industrial markets: Miami · Fort Lauderdale · West Palm Beach · Tampa · Orlando · Jacksonville · Lakeland · Sarasota · Fort Myers · Naples · Melbourne · Port St. Lucie. See all Florida markets →

Sources cited on this page

Public Law 119-21, 139 Stat. 72 (July 4, 2025), enacted text, §§ 70301, 70306, 70307, 70601 · Internal Revenue Code §§ 1(h), 163(j), 168, 179, 461(l), 469, 1031, 1245, 1250 · IRS Notice 2026-11, Interim Guidance on the Additional First Year Depreciation Deduction under § 168(k) · IRS Revenue Procedure 2025-32 (2026 inflation adjustments) · IRS Publication 5653, Cost Segregation Audit Technique Guide (rev. 2-6-2025) · Revenue Procedure 87-56 · Revenue Ruling 90-38 · Treasury Decision 9935 and Treas. Reg. §§ 1.1031(a)-3, 1.1031(k)-1(g)(7)(iii) · Treasury Decision 9874 and Treas. Reg. § 1.168(k)-2(g)(5)(iii)(A) · Treas. Reg. § 1.1245-4(d) · Peco Foods, Inc. v. Commissioner, T.C. Memo. 2012-018, aff’d 522 F. App’x 840 (11th Cir. 2013) · Chief Counsel Advice 201805001 · Fla. Stat. § 196.183 and Florida Department of Revenue guidance on tangible personal property. Market context is drawn from Ironmark’s own quarterly research. Page prepared August 28, 2026. Informational only — not tax, legal, accounting or appraisal advice.