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Section 179 and Bonus Depreciation: What Changed, and What South Carolina Does Not Follow
Both write-offs are larger and more permanent than they have been for years. Neither of them is a reason to buy something, and one of them does considerably less in South Carolina than it does on the federal return.
These are the figures for tax years beginning in 2026. Both limits are indexed and the rules underneath them were rewritten recently, so this is one of the areas where a two-year-old article is actively misleading rather than merely stale.
What each one does
Section 179 — an election, asset by asset
Section 179 lets you elect to expense the cost of qualifying property in the year it is placed in service rather than depreciate it. For tax years beginning in 2026 the maximum is $2,560,000, reduced dollar for dollar once the cost of qualifying property placed in service in the year exceeds $4,090,000. Above roughly $6.65 million of purchases, the deduction is gone entirely.
It is elective and it is granular: you choose which assets, and you can expense part of an asset's cost and depreciate the rest. That flexibility is the reason it survives alongside bonus depreciation rather than being made redundant by it.
Bonus depreciation — automatic, and now permanent
The One, Big, Beautiful Bill replaced the scheduled phase-down of bonus depreciation with a permanent 100% first-year deduction for qualified property acquired after January 19, 2025. Treasury and the IRS issued interim guidance on it in Notice 2026-11. For property placed in service during the first tax year ending after January 19, 2025, a taxpayer could elect 40% instead of 100% — 60% for certain longer production period property and aircraft — which is an unusual election to have available and worth knowing existed.
Bonus applies automatically to eligible property unless you elect out, and the election out is made by class of property rather than asset by asset.
Choosing between them
With both at effectively full expensing, the difference is no longer about how much. It is about three things.
- Section 179 is limited to taxable income from the active conduct of a trade or business. It cannot create or increase a loss; the excess carries forward. Bonus depreciation has no such limit and can create a net operating loss.
- Section 179 lets you pick individual assets and partial amounts. Bonus is all-or-nothing within a class.
- State treatment differs, and in South Carolina it differs a great deal.
A profitable business that wants the deduction now and no loss usually reaches for Section 179. A business deliberately generating a loss — to carry forward, or against other income where the rules permit — needs bonus. A business that wants a large federal deduction and a manageable state return needs to look at the third point before deciding.
The South Carolina addback
South Carolina does not recognize the bonus depreciation allowed by IRC Section 168(k). In the year the property is placed in service, the difference between the federal depreciation deduction and what the deduction would have been without bonus is added back on the South Carolina return.
Three consequences follow, and only the first is obvious:
- The state deduction in year one is far smaller than the federal one. A 100% federal write-off is not a 100% South Carolina write-off.
- Your South Carolina adjusted basis in the asset is higher than your federal basis, and stays that way. Two sets of depreciation schedules, for as long as you own it.
- The deduction is not lost. Additional depreciation is available for South Carolina purposes across the remaining years of the asset's life. It is timing, not disallowance — but it is timing that runs for the whole recovery period.
Section 179 has historically been treated more favorably by South Carolina than bonus depreciation, which is a further reason the choice between them is a state question as much as a federal one. And a caution specific to this year: H. 4216 rewrote the South Carolina individual income tax for 2026, decoupling the state from federal deductions and making federal adjusted gross income the starting point, and the SCDOR has said further guidance is coming. Confirm the current mechanics for 2026 rather than relying on how the addback was reported on an earlier form.
The rules that trip people
Placed in service, not purchased
The deduction attaches to the year the asset is placed in service — available and ready for its intended use. Ordered in November, paid for in December, delivered in January is a next-year deduction. A machine sitting uninstalled in a warehouse on December 31 has not been placed in service.
Vehicles have their own regime
For 2026, the amount of an SUV's cost that can be taken under Section 179 is capped at $32,000. Passenger automobiles are subject to separate annual depreciation limits. Vehicles are listed property, so business use has to be documented, and if business use drops to 50% or less in a later year, part of the earlier deduction is recaptured as ordinary income. Contemporaneous mileage records are the difference between a deduction and an argument.
Recapture on disposal
Expensing does not make the asset free. When you sell it, the deduction you took comes back as ordinary income to the extent of the gain. Businesses that expense heavily and turn equipment over regularly are managing a recurring recapture problem rather than a one-off deduction.
The point that gets lost in December
A deduction returns your marginal rate. Spending $60,000 on equipment you did not need in order to avoid tax converts $60,000 of cash into an asset plus somewhere between $15,000 and $25,000 of tax saved. If the equipment earns its keep, expensing is a genuine cash flow advantage worth timing carefully. If it does not, the tax tail has wagged a fairly large dog.
The useful version of this conversation happens before the purchase, and it starts with whether the business needs the asset. The election is the easy part.
Sources
- IRS — Publication 946, How to Depreciate Property
- IRS — Guidance on the additional first year depreciation deduction under the One, Big, Beautiful Bill
- IRS — Rev. Proc. 2025-32 (Internal Revenue Bulletin 2025-45)
- IRS — Instructions for Form 4562
- SCDOR — Information about H. 4216
- SCDOR — Individual Income Tax
The information on this site is general in nature and is not tax, legal, or accounting advice for your situation. Tax law changes and the right answer depends on facts we would need to review with you. Please speak with a qualified professional before acting on anything you read here.
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