Analysis of Revenue Procedure 2026-15: Passenger Automobile Depreciation Limitations and Lease Inclusion Amounts for 2026
For tax professionals advising clients on the acquisition or leasing of business vehicles, Revenue Procedure 2026-15 is the essential annual guidance that updates depreciation limits and lease inclusion amounts. According to the guidance, "This revenue procedure provides: (1) two tables of limitations on depreciation deductions for owners of passenger automobiles placed in service by the taxpayer during calendar year 2026; and (2) a table of dollar amounts that must be used to determine income inclusions by lessees of passenger automobiles with a lease term beginning in calendar year 2026".
For practitioners applying these rules, it is important to note that "the term ‘passenger automobiles’ includes trucks and vans".
Statutory Background and Inflation Adjustments
The Internal Revenue Code (IRC) mandates the annual publication of these tables. Specifically, "For owners of passenger automobiles, § 280F(a) imposes dollar limitations on the depreciation deduction for the year the taxpayer places the passenger automobile in service and for each succeeding year".
To account for economic shifts, Congress requires an annual indexation of these limits. The procedure states that "[f]or passenger automobiles placed in service after 2018, § 280F(d)(7) requires the Internal Revenue Service to increase the amounts allowable as depreciation deductions by a price inflation adjustment amount that is determined using the automobile component of the Chained Consumer Price Index for All Urban Consumers published by the Department of Labor (C-CPI-U)". For the 2026 calendar year, this calculation results in an "automobile price inflation adjustment for 2026 for passenger automobiles" of 23.468 percent, which is applied to the base limits and rounded to the nearest $100.
Interaction with Section 168(k) Bonus Depreciation
A critical component of advising clients on vehicle purchases is the interaction between IRC § 280F limitations and IRC § 168(k) additional first-year depreciation. The landscape for 2026 includes considerations under recent legislation. As detailed in the procedure, "Section 168(k), as amended by Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act (OBBBA), applies to property acquired and placed in service after January 19, 2025". Under this amendment, "Section 168(k)(1)... allows an additional first year depreciation deduction under § 167(a) equal to 100 percent of the property’s adjusted basis".
For property placed in service in 2026 but subject to the pre-OBBBA rules (acquired before January 20, 2025), the applicable bonus percentage phases down to 20 percent.
Regardless of whether the old or new § 168(k) applies, if a vehicle qualifies for bonus depreciation, the statute provides a specific bump to the first-year limit: "For qualified property acquired and placed in service after September 27, 2017, § 168(k)(2)(F)(i) increases the first-year depreciation allowed under § 280F(a)(1)(A)(i) by $8,000".
However, practitioners must remain vigilant regarding exceptions. The § 168(k) additional first-year deduction does not apply in 2026 if the taxpayer: "(1) did not use the passenger automobile during 2026 more than 50 percent for business purposes; (2) elected out of the § 168(k) additional first year depreciation deduction pursuant to § 168(k)(7) for the class of property that includes passenger automobiles; (3) acquired a used passenger automobile and the acquisition of such property did not meet the acquisition requirements in § 168(k)(2)(E) and § 1.168(k)-2(b)(3)(iii) of the Income Tax Regulations; or (4) acquired the passenger automobile before September 28, 2017".
Depreciation Limitation Tables for 2026
The IRS provides two distinct tables for owners depending on whether the vehicle is subject to the § 168(k) bonus depreciation deduction.
Table 1 is used for passenger automobiles "acquired by the taxpayer after September 27, 2017, and placed in service by the taxpayer during calendar year 2026, for which the § 168(k) additional first year depreciation deduction applies". The procedure notes that these limitations "apply regardless of whether the § 168(k) additional first year depreciation deduction is allowed under former § 168(k) or § 168(k) as amended by the OBBBA".
REV. PROC. 2026-15 TABLE 1 DEPRECIATION LIMITATIONS FOR PASSENGER AUTOMOBILES ACQUIRED AFTER SEPTEMBER 27, 2017, AND PLACED IN SERVICE DURING CALENDAR YEAR 2026, FOR WHICH THE § 168(k) ADDITIONAL FIRST YEAR DEPRECIATION DEDUCTION APPLIES
| Tax Year | Amount |
|---|---|
| 1st Tax Year | $20,300 |
| 2nd Tax Year | $19,800 |
| 3rd Tax Year | $11,900 |
| Each Succeeding Year | $7,160 |
Table 2 is to be used "for a passenger automobile placed in service by the taxpayer during calendar year 2026 for which no § 168(k) additional first year depreciation deduction applies".
REV. PROC. 2026-15 TABLE 2 DEPRECIATION LIMITATIONS FOR PASSENGER AUTOMOBILES PLACED IN SERVICE DURING CALENDAR YEAR 2026 FOR WHICH NO § 168(k) ADDITIONAL FIRST YEAR DEPRECIATION DEDUCTION APPLIES
| Tax Year | Amount |
|---|---|
| 1st Tax Year | $12,300 |
| 2nd Tax Year | $19,800 |
| 3rd Tax Year | $11,900 |
| Each Succeeding Year | $7,160 |
Statutory Authority for Lessee Income Inclusions
For clients leasing passenger automobiles, IRC § 280F(c)(2) "requires a reduction to the amount allowable as a deduction to the lessee of a leased passenger automobile". This rule ensures parity between leasing and purchasing. The text states, "Pursuant to § 280F(c)(3), the reduction must be substantially equivalent to the limitations on the depreciation deductions imposed on owners of passenger automobiles".
From a compliance standpoint, "Under § 1.280F-7(a), this reduction is accomplished by requiring the lessee to include in gross income an amount determined by applying a formula to a dollar amount obtained from a table". The IRS supplies Table 3 to fulfill this requirement.
Income Inclusion Table for 2026 Leases
Table 3 "provides the dollar amount used by lessees of passenger automobiles with a lease term beginning in 2026 to determine the income inclusion amount for those passenger automobiles," based on the vehicle’s fair market value.
REV. PROC. 2026-15 TABLE 3 DOLLAR AMOUNTS FOR PASSENGER AUTOMOBILES WITH A LEASE TERM BEGINNING IN CALENDAR YEAR 2026
| Fair Market Value Over | Fair Market Value Not Over | 1st Tax Year During Lease | 2nd Tax Year During Lease | 3rd Tax Year During Lease | 4th Tax Year During Lease | 5th Tax Year During Lease & Later |
|---|---|---|---|---|---|---|
| $62,000 | $64,000 | 8 | 15 | 21 | 25 | 27 |
| 64,000 | 66,000 | 19 | 38 | 56 | 66 | 76 |
| 66,000 | 68,000 | 29 | 62 | 91 | 108 | 123 |
| 68,000 | 70,000 | 40 | 86 | 125 | 149 | 172 |
| 70,000 | 72,000 | 51 | 109 | 160 | 191 | 220 |
| 72,000 | 74,000 | 61 | 133 | 195 | 232 | 268 |
| 74,000 | 76,000 | 72 | 156 | 230 | 274 | 316 |
| 76,000 | 78,000 | 83 | 179 | 265 | 316 | 364 |
| 78,000 | 80,000 | 93 | 203 | 299 | 358 | 412 |
| 80,000 | 85,000 | 112 | 244 | 360 | 431 | 496 |
| 85,000 | 90,000 | 139 | 302 | 447 | 535 | 617 |
| 90,000 | 95,000 | 166 | 361 | 534 | 639 | 737 |
| 95,000 | 100,000 | 192 | 420 | 621 | 743 | 858 |
| 100,000 | 110,000 | 232 | 507 | 752 | 900 | 1,038 |
| 110,000 | 120,000 | 286 | 624 | 926 | 1,108 | 1,279 |
| 120,000 | 130,000 | 339 | 742 | 1,099 | 1,317 | 1,520 |
| 130,000 | 140,000 | 392 | 859 | 1,273 | 1,526 | 1,760 |
| 140,000 | 150,000 | 446 | 976 | 1,447 | 1,734 | 2,001 |
| 150,000 | 160,000 | 499 | 1,093 | 1,621 | 1,943 | 2,242 |
| 160,000 | 170,000 | 553 | 1,210 | 1,795 | 2,151 | 2,483 |
| 170,000 | 180,000 | 606 | 1,328 | 1,968 | 2,360 | 2,723 |
| 180,000 | 190,000 | 659 | 1,445 | 2,142 | 2,569 | 2,964 |
| 190,000 | 200,000 | 713 | 1,562 | 2,316 | 2,777 | 3,205 |
| 200,000 | 210,000 | 766 | 1,679 | 2,490 | 2,986 | 3,445 |
| 210,000 | 220,000 | 820 | 1,796 | 2,664 | 3,194 | 3,686 |
| 220,000 | 230,000 | 873 | 1,913 | 2,838 | 3,403 | 3,927 |
| 230,000 | 240,000 | 926 | 2,031 | 3,012 | 3,610 | 4,168 |
| 240,000 | 250,000 | 980 | 2,148 | 3,185 | 3,820 | 4,408 |
| 250,000 | 260,000 | 1,033 | 2,265 | 3,360 | 4,027 | 4,650 |
| 260,000 | 270,000 | 1,086 | 2,382 | 3,534 | 4,236 | 4,890 |
| 270,000 | 280,000 | 1,140 | 2,499 | 3,708 | 4,444 | 5,131 |
| 280,000 | 290,000 | 1,193 | 2,617 | 3,881 | 4,653 | 5,372 |
| 290,000 | 300,000 | 1,247 | 2,733 | 4,056 | 4,862 | 5,612 |
| 300,000 | 310,000 | 1,300 | 2,851 | 4,229 | 5,070 | 5,854 |
| 310,000 | 320,000 | 1,353 | 2,968 | 4,403 | 5,279 | 6,094 |
| 320,000 | 330,000 | 1,407 | 3,085 | 4,577 | 5,487 | 6,335 |
| 330,000 | 340,000 | 1,460 | 3,202 | 4,751 | 5,696 | 6,576 |
| 340,000 | 350,000 | 1,514 | 3,319 | 4,925 | 5,904 | 6,817 |
| 350,000 | 360,000 | 1,567 | 3,437 | 5,098 | 6,113 | 7,057 |
| 360,000 | 370,000 | 1,620 | 3,554 | 5,273 | 6,321 | 7,298 |
| 370,000 | 380,000 | 1,674 | 3,671 | 5,446 | 6,530 | 7,539 |
| 380,000 | 390,000 | 1,727 | 3,788 | 5,621 | 6,738 | 7,779 |
| 390,000 | 400,000 | 1,781 | 3,905 | 5,794 | 6,947 | 8,020 |
| 400,000 | 410,000 | 1,834 | 4,022 | 5,969 | 7,155 | 8,261 |
| 410,000 | 420,000 | 1,887 | 4,140 | 6,142 | 7,364 | 8,501 |
| 420,000 | 430,000 | 1,941 | 4,257 | 6,316 | 7,572 | 8,742 |
| 430,000 | 440,000 | 1,994 | 4,374 | 6,490 | 7,781 | 8,983 |
| 440,000 | 450,000 | 2,047 | 4,491 | 6,664 | 7,990 | 9,223 |
| 450,000 | 460,000 | 2,101 | 4,608 | 6,838 | 8,198 | 9,464 |
| 460,000 | 470,000 | 2,154 | 4,726 | 7,011 | 8,407 | 9,705 |
| 470,000 | 480,000 | 2,208 | 4,843 | 7,185 | 8,615 | 9,946 |
| 480,000 | 490,000 | 2,261 | 4,960 | 7,359 | 8,824 | 10,186 |
| 490,000 | 500,000 | 2,314 | 5,077 | 7,533 | 9,033 | 10,427 |
| 500,000 | and over | 2,368 | 5,194 | 7,707 | 9,241 | 10,668 |
Practitioners should ensure they review the specific acquisition requirements found in § 168(k)(2)(E) and § 1.168(k)-2(b)(3)(iii), along with the date property is placed in service to accurately advise on depreciation and inclusions for 2026.
Prepared with assistance from NotebookLM.
