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    • Home
    • Cost Seg - Overview Info
      • Cost Segregation Overview
      • Cost Seg Methodology
      • 100% Bonus Depreciation
      • Step-Up Basis Cost Seg
      • 1031 Basis & Cost Seg
      • QIP - Qualified Improv. P
      • QPP - Qual Prod. Property
    • Cost Seg - Property Types
      • Cost Seg - Apartment
      • Cost Seg - CRE & Hotel
      • Cost Seg - Industrial M
      • Cost Seg - Data Centers
      • Cost Seg - Nuclear Plant
      • Cost Seg - Infra Overview
      • Cost Seg - Renew Energy
      • CS For Renovation, UOP
      • CS Partial Disposition
    • Qualifications
    • Contact Us
  • Home
  • Cost Seg - Overview Info
    • Cost Segregation Overview
    • Cost Seg Methodology
    • 100% Bonus Depreciation
    • Step-Up Basis Cost Seg
    • 1031 Basis & Cost Seg
    • QIP - Qualified Improv. P
    • QPP - Qual Prod. Property
  • Cost Seg - Property Types
    • Cost Seg - Apartment
    • Cost Seg - CRE & Hotel
    • Cost Seg - Industrial M
    • Cost Seg - Data Centers
    • Cost Seg - Nuclear Plant
    • Cost Seg - Infra Overview
    • Cost Seg - Renew Energy
    • CS For Renovation, UOP
    • CS Partial Disposition
  • Qualifications
  • Contact Us

Cost Segregation Study

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Step-Up Basis Cost Segregation

Re-Originating Depreciation Through Fair Market Value Reset

 

When income-producing real property passes through an estate, the tax basis is often reset to fair market value (FMV) as of the date of death (or alternate valuation date).


This step-up in basis creates a rare and powerful opportunity to re-originate depreciation, even for properties that were previously fully depreciated or never subjected to cost segregation.

We treat estate-related cost segregation not as a continuation of prior schedules, but as a discipline of capital re-origination grounded in valuation law and depreciation mechanics.


Why Inherited Property Is Structurally Different

Unlike acquisitions or exchanges, estate-passed properties introduce a fundamentally new depreciation framework:

  • Prior owner’s depreciation history does not carry forward
  • Basis is reset to FMV under IRC §1014
  • Depreciation is restarted from the inherited value
  • Assets may now qualify for accelerated recovery even if previously exhausted
     

This allows cost segregation to be re-initiated from a clean capital base, anchored in estate valuation — not historical cost.


The Economic Opportunity for Heirs

For heirs, beneficiaries, and family offices, step-up basis cost segregation can:

  • Restore depreciation to long-held legacy properties
  • Generate substantial non-cash tax deductions
  • Improve post-inheritance cash flow
  • Support refinancing, recapitalization, and portfolio restructuring
  • Re-align tax depreciation with current economic reality
     

This is one of the most powerful — and underutilized — applications of cost segregation.


Our Methodology: Valuation-Driven Depreciation Re-Origination

Estate-based cost segregation begins not with engineering — but with valuation discipline.


1. Establishing Fair Market Value (FMV)

Our process begins with a defensible FMV determination as of:

  • Date of death, or
  • Alternate valuation date (when elected)
     

This may involve:

  • Appraisal-based valuation
  • Review of estate tax filings (Form 706)
  • Reconciliation of market, income, and cost approaches
  • Coordination with estate attorneys, fiduciaries, and CPAs
     

FMV becomes the new depreciation foundation, not historical cost.


2. Land & Improvement Allocation Based on FMV

Once FMV is established, we allocate:

  • Non-depreciable land
  • Depreciable building
  • Site improvements
     

Using:

  • Market-based land abstraction
  • Residual valuation techniques
  • Appraisal discipline
     

This ensures depreciation applies only to properly depreciable capital derived from the new FMV basis.


3. Fresh Cost Segregation on the Reset Basis

We then perform a full cost segregation study based on the FMV-derived improvement basis:

  • Reclassifying qualifying assets into §1245 and §1250 categories
  • Applying applicable bonus depreciation and recovery rules
  • Establishing new recovery lives
  • Fully independent of the decedent’s depreciation history
     

This is not an adjustment — it is a new depreciation origination event.


Why Prior Depreciation Does Not Limit the Heirs

A common misconception is that depreciation “runs out” with the property.

In reality:

  • Depreciation belongs to the taxpayer, not the asset
  • Upon inheritance, the property receives a new tax basis
  • The heir’s depreciation is independent of the decedent’s schedules
     

This allows cost segregation to be applied even when:

  • The property is decades old
  • Prior depreciation was fully exhausted
  • No prior cost segregation existed
     

When Step-Up Basis Cost Segregation Is Most Valuable

  • Long-held family real estate
  • Fully depreciated legacy assets
  • Commercial, multifamily, hospitality, and mixed-use properties
  • Industrial and special-purpose assets
  • Properties entering refinancing or recapitalization
  • Assets being repositioned or restructured post-inheritance
     

IRS-Defensible Documentation

Our estate-related cost segregation engagements emphasize:

  • Valuation-grade FMV support
  • Full reconciliation to estate tax filings
  • Clear separation from decedent depreciation
  • Audit-ready classification schedules
  • Documentation suitable for fiduciary, CPA, and IRS review
     

This ensures the depreciation reset is:
✔ Legally supportable
✔ Institutionally defensible
✔ Sustainable under audit


Why This Requires Valuation Discipline

Generic cost segregation firms are typically not equipped to:

  • Establish FMV
  • Interpret estate tax filings
  • Reconcile depreciation across ownership boundaries
  • Coordinate with fiduciaries and estate counsel
     

This is why step-up basis cost segregation belongs in a valuation-centric practice, not a tax-only workflow.


Bottom Line

Step-up basis cost segregation is not a tax strategy.
It is a capital re-origination discipline rooted in valuation law and depreciation mechanics.

At US Valuation, estate-related cost segregation is performed with:

  • Valuation-anchored FMV establishment
  • Appraisal-based land abstraction
  • Fresh depreciation origination
  • IRS-defensible documentation
     

Discuss Step-Up Basis Cost Segregation Feasibility

If you have inherited income-producing property, a properly structured cost segregation study based on FMV may materially improve after-tax cash flow — but only when executed with valuation discipline and estate alignment.

👉 Request a Step-Up Basis Cost Segregation Consultation

Copyright © 2018     CostSegregationExpert.com - All Rights Reserved.  Serving Nationwide — Engineering-Based and Appraisal-Based Cost Segregation Studies for Infrastructures (Data Centers, Power & Nuclear Assets) and Commercial, Industrial, Manufacturing, and Multifamily Assets.   Certified General Real Estate Appraiser in States of CA, NV, TX, OR, WA, AZ, HI, GA, VA, DC, MD.


 David Hahn, CVA, ASA, MAFF, CCIM, CM&AA, MBA 

 CVA - Certified Business Valuation Analyst --- (IRS Tax Valuation Expert)

ASA - Accredited Senior Appraiser 

CCIM - Certified Commercial Investment Member

CM&AA - Certified Merger & Acquisition Advisor
MAFF - Master Analyst in Financial Forensics
State Certified General RE Appraiser in California, Arizona, Nevada

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