A, B and C form ABC LLC and fund it with cash. ABC LLC takes the cash and acquires a business, DRE LLC, some time between now and 12/31. ABC LLC contributes DRE LLC to a newly formed corporation, ABC Co., on 1/1.
Can ABC LLC take bonus depreciation in 2025 on the business assets, which will be deductible to A, B and C? But is there a step-transaction issue here? Will the IRS apply the step transaction doctrine to disallow this?
Partnership bonus depreciation and corporate step transaction doctrine issue?
byu/No-write-off intax
Posted by No-write-off