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.