ARE GOLF CLUBS MISSING A TAX BENEFIT?
William Ellis, CPA
Golf Clubs are continually improving their facilities similar, in many respects, to retail operations. Clubhouses are updated, renovated or simply refreshed. Golf courses are renovated or simply modified almost every year. Most of these costs are typically included in a club’s “capital budget” and are routinely capitalized. Previously, this has been consistent with tax authorities on the issue of capitalization versus expensing.
If your Golf Club is not tax exempt or is subject to current income taxes at the corporate or investor level, the Tangible Property Regulations (“TPR”) effective in 2014 may provide significant benefits – specifically the authority to currently deduct many clubhouse and golf course “improvements”.
The TPR regulations do not address non-building improvements in detail and are complex but some simple truths can be stated. Golf course improvements such laser-leveling tees, converting all greens to new mini Bermuda grasses, and bunker renovations, for example, likely can be expensed under the regulations. Clubhouse replacements of a major HVAC unit when there are 4 HVAC units, most clubhouse renovations/refreshments and resurfacing parking lots, for example, are also likely to be eligible for a current expense.
Simple point: If you are the original owner or have owned the property for several years AND if most if not all your “capital budget” improvements to the clubhouse and golf course are being capitalized, a simple TPR review should be considered. This can be confirmed by actions taken with your 2014 tax return and anticipated capitalization of 2015 costs. Certain rules and elections must be followed. Don’t miss out on some benefits of the new TPR regulations.
The author, Bill Ellis, is a retired former tax partner with EY and KPMG first practicing tax in 1972. He formulated, organized and led the KPMG and NGCOA efforts in 1999-2001 that resulted in the first IRS Industry Issue Resolution and RR 2001-60 providing the ability to depreciate substantial costs of golf course land improvements. He primarily advises owners of amenities that are not tax exempt. Bill can be contacted at tpr@williamellis.com