Office Buildings
Office buildings are generally 39-year nonresidential real property. There is no IRS office matrix. Metro National classified some partitions and lighting as personal property on one owner’s facts. Later interiors may be qualified improvement property if §168(e)(6) is met.
Educational information, not tax advice.
Updated 2026-10-14
Key takeaways
- The structure is typically 39-year nonresidential real property, straight line, mid-month.
- Publication 946 class 00.11 assigns office furniture, fixtures, and equipment a 7-year GDS period; computers are often class 00.12, 5-year.
- Metro National Corp. v. Commissioner, T.C. Memo. 1987-38, is a memorandum opinion about one owner’s office and medical buildings, not an office playbook.
- Building-protection security is generally a structural building system; decorative lighting turns on whether it is the primary light source.
- QIP can apply to later interior work the taxpayer makes, not to the original shell.
- Bonus depreciation as of 2026 can apply to qualified furniture, QIP, and site work acquired after January 19, 2025, not to the 39-year building.
Speculative towers and small professional buildings share a 39-year shell. Treas. Reg. §1.48-1(e)(1) lists office buildings among examples of buildings. Structural components include partitions, floors and permanent coverings, windows and doors, central HVAC, plumbing fixtures, electric wiring and lighting fixtures, elevators, and sprinklers. Those items stay with the building unless a regulation exception or case-law allocation applies on the facts.
There is no office-industry matrix in Publication 5653. Carpet, demountable partitions, and decorative lighting are therefore decided under Treas. Reg. §1.48-1, the Whiteco permanence factors, and whatever analogous matrix rows a study cites with a caveat. Retail, restaurant, and residential matrices treat certain carpet and VCT as removable for those industries; the pharmaceutical matrix treats permanently adhered VCT and carpet as building. An office floor is not automatically any of those rows.
Publication 946 class 00.11 covers office furniture, fixtures, and equipment that are not structural components — desks, files, safes, communications equipment — with a 7-year GDS period. Class 00.12 covers information systems (computers and peripherals) at 5 years. Rev. Rul. 2003-81 requires checking the asset category first. A lessor generally uses the lessee’s activity class for activity-category property, as the ATG notes in Chapter 6.C.5.
Metro National allowed movable gypsum partitions and some decorative lighting, and denied atrium storefront walls, lay-in ceilings, and lawn sprinkler heads, on the facts of that case. It is a memorandum opinion. It does not hold that every office partition is personal property or that every sprinkler head is a land improvement. Later cases, including AmeriSouth in an apartment setting, show that aggressive component lists can fail when permanence and building-operation facts go the other way.
Parking lots are typically class 00.3, 15-year. Parking structures are 39-year buildings in the retail matrix and ATG Chapter 8.B. Building-protection security systems are a building system under Treas. Reg. §1.263(a)-3(e)(2)(ii)(B)(7) and are generally §1250 in the ATG security rows. Data cabling that serves equipment rather than the structure is 5-year in the residential matrix; offices use that row only by analogy.
This page is educational information, not tax advice. Proposed Super Intelligence office take-offs are explanatory only.
Partitions, ceilings, and lighting
Treas. Reg. §1.48-1(e)(2) lists partitions as structural components. Senate report language quoted in the ATG distinguishes movable and removable partitions. Room-dividing partitions that control traffic are building in the ATG matrices regardless of height. Readily removable and reusable partitions can be personal property when the facts match Metro National or the report language — not when they are the original corridor walls.
General lighting and exit lighting are structural. Decorative lighting can be personal property if other sources would provide sufficient light if it were turned off. Primary office lighting is not decorative because it has a shade. Ceiling grids and lay-in tile were denied in Metro National on those facts.
Qualified improvement property
Section 168(e)(6) defines QIP as an improvement made by the taxpayer to an interior portion of a building that is nonresidential real property, placed in service after the building was first placed in service. It excludes enlargements, elevators and escalators, and internal structural framework. QIP is 15-year property and is bonus-eligible. The original building is not QIP.
A tenant’s own interior improvements can qualify for the tenant; a landlord’s work can qualify for the landlord. Publication 946 describes QIP as improvements “made by you.” Who paid, who owns the improvement, and whether an allowance was a lease term are CPA questions. Do not treat the first-generation spec suite as QIP.
Documentation
Stacking plans, tenant improvement ledgers, furniture invoices kept out of the construction contract, lighting schedules that distinguish decorative from general fixtures, and security drawings that show building protection versus information-security devices are the useful records. Acquisition files need land first and a field inspection.
Peco Foods warns that a written §1060 allocation in an asset purchase of a going business can block a later study from subdividing the same assets. Not every office purchase is a §1060 deal. When a written schedule exists, read it before commissioning take-offs.
Bonus depreciation as of 2026
Qualified property acquired after January 19, 2025 is eligible for 100% bonus depreciation under Notice 2026-11. The 39-year office shell is not qualified property. Furniture in class 00.11 or 00.12, 15-year site work, and QIP can be if the other §168(k) rules are met. Binding contracts dated on or before January 19, 2025 stay on the prior phase-down.
Property required to use ADS, including the real property of an electing real property trade or business, is not bonus-eligible. Confirm elections and acquisition dates with a CPA. Educational information, not tax advice.
Limits
There is no IRS office matrix. Analogies to retail flooring or restaurant millwork must be labeled as analogies. Do not invent a typical office reclass percentage, and do not say a partition “is” 5-year property in every tower.
Metro National and AmeriSouth can both be right on their facts. Proposed Super Intelligence office screens are explanatory only.
Sources
- 1
- 2Metro National Corp. v. Commissioner, T.C. Memo. 1987-38(opens in a new tab)
IRS written determination that summarizes the decision.
- 3
- 4IRS Publication 946 — How To Depreciate Property (2025)(opens in a new tab)
Appendix B reproduces the Rev. Proc. 87-56 class lives.
- 5
- 6