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Accelerated Depreciation and the Allocation of Income Taxes

Author(s): Sidney Davidson


Source: The Accounting Review, Vol. 33, No. 2 (Apr., 1958), pp. 173-180
Published by: American Accounting Association
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The AccountingReview
VOL. XXXIII APRIL, 1958 NO. 2

ACCELERATED DEPRECIATION AND THE


ALLOCATION OF INCOME TAXES
SIDNEY DAVIDSON
Professor, The Johns Hopkins University

INthe April, 1957 issue of this Journal with distinct operating divisions which are
Maurice Moonitz presented an analy- virtually separate firms. If attention is
sis of "Income Taxes in Financial focused on the income of the entity, the
Statements"' which urged the allocation of liability for future taxes is likely to be en-
income taxes among statement items in a tirely non-existent in most cases.
variety of cases. In the July, 1957 issue, In deciding whether or not inter-period
Thomas M. Hill2 indicated the reasons for allocation is appropriate and whether a
his opposition to the suggested inter-period liability exists, Moonitz points out two
allocation of income taxes. Both articles controlling questions:
agree that the most important of the areas (a) Are tax rates expected to remain at sub-
of controversy over inter-period allocation stantially their current levels? and
arises from the use of an accelerated-depre- (b) Is taxable income expected to emerge each
ciation method for* tax purposes and year in the foreseeable future?
straight-line depreciation for financial re-
If these two criteria were indeed control-
porting purposes. These comments will be
ling, then recognition of a liability for
confined to a consideration of that ques-
future taxes might be appropriate. Most
tion only.
firms can answer both questions affirma-
In his analysis of this accelerated depre-
tively with at least as much confidenceas
ciation case Professor Moonitz seeks to as-
they place, for example, in the service life
sociate the amount of income tax charges
estimates that control the amount of their
with income produced by individual assets.
This is a well-nigh impossible task for al-
depreciation charges. However, two other
criteria precede those listed by Moonitz.
most all firms. Income typically results
They are:
from a successful blending of a variety of
economic resources, all of which are neces- (1) Are tax rules for depreciation methods ex-
sary to achieve the desired final result. Ef- pected to remain as generous as they now
are? and
forts to allocate the income total to spe- (2) Will a policy of regular investment in
cific assets are likely to be fruitless or mis- assets subject to depreciation be main-
leading. In the usual case income can only tained?
be associated with the firm as a whole or
If the answer to these two questions is af-
I THE AccOUNTING REVIW, April, 1957, pp. 175-
2183
firmative, then there will be no future tax
2 THE~
AccOTJNTING
RyvImw, July, 1957,pp. 357-361. liability and questions (a) and (b) need not
173

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174 The Accounttng Ievteew

be raised. Only if questions (1) and (2) ment of one machine each year has been
cannot be answered favorably is there any made. In company with almost all other
need to consider the other criteria. American firms, our firm has used the
If we focus attention on the total collec- straight-line depreciation method for fi-
tion of depreciating assets of the taxable nancial accounting and tax accounting for
entity rather than on one, or a small many years. Thus the depreciation deduc-
group, of its depreciating assets, the ques- tion in its tax return and income statement
tion is seen in proper perspective. In the in year 0 (1953) and preceding years was
next section the depreciation charges of an $1,500.
artificially simple static firm and of a In year 1 (1954) the firm decided to
steadily growing one will be considered. avail itself of the opportunity to use the
Subsequent sections will deal with the sum-of-the-years-digits method4 of depre-
standards for expense and liability recog- ciation for newly acquired assets for tax
nition and the probability of the non-allo- purposes but it decided to continue to use
cation criteria being realized. straight-line depreciation for financial-re-
Throughout the discussion that follows porting purposes.The depreciationcharges
the only type of allocation considered is from year 0 onward are indicated in Table
inter-period allocation of income taxes 1. During the fouryear periodof transition'
where an accelerated-depreciation method to the new arrangement, depreciation
is used for tax purposes and the straight- deductions for tax purposes exceed those
line method is used for financial reporting for financial-reportingpurposes; in years 5
purposes. This problem would lose a good and 6 and in all years -thereafterdepredia-
bit of its significance, as Moonitz correctly tion deductions for tax and financial ac-
points out, if income taxes were treated as counting are identical, if our two condi-
a distribution, rather than a partial deter- tions of no change in the depreciation pro-
minant, of income. However, he accepts visions of the tax law and continued re-
the premise that income taxes are an ex- placement of retired assets are met.
pense. This analysis will be couched in the Under these conditions, should an entry
same terms, although, for reasons set forth chargingincome and recognizinga liability
elsewhere, I feel treatment of income taxes for "income taxes payable in the future"
as an income distribution results in a more be made in years 1 through 4? Assuming a
meaningful presentation of income.3 50% tax rate, the entry in year 1 would be:
Income tax charges ....... ..... 100
STATIC AND STEADILY Income tax payable in the future .............. 100
GROWING FIRMS 50% of the "extra" depreciation of $200. This
assumes a previous entry recognizing the tax
Although a completely static firm is un- currently payable has been made.
likely to be encountered in the real world, In years 2, 3 and 4 similar entries in the
its artificial simplicity is useful as an ex-
pository device. Let us consider such a 4 If the double-declining-balance method were used,
firm which owns 5 depreciating assets, substantially similar results would be achieved. The
sum-of-the-years-digits method is used in this and
each costing $1,500. The assets were ac- future illustrations because it gives a somewhat greater
quired at the rate of one each year on suc- degree of acceleration and seems to be used somewhat
more widely. Cf. Accounting Trends and Techniques,
cessive New Year's Days and all have serv- Tenth Edition (1956), p. 156.
6 The transition to accelerated depreciation will be
ice lives of five years with zero salvage
accomplished in n-1 years, where n is equal to esti-
value. Since this is a static firm, replace- mated service life of the asset. In a more realistic case of
a firm with a heterogeneous group of assets, the great
I See Mason and Davidson, Fundamentals of Ac- bulk of the transition will be completed in n-1 years,
counting, 3rd Edition, p. 168. where n is equal to weighted average service life.

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AcceleratedDepreciation and Taxes 175
TABLEI
OFA STATICFIRm
CHARGES
DEPRECIATION

Assets DepreciationChargein Year:


Acquired Costof Assets
in Year 0 1 2 3 4 5 6

A. Tax Return Depreciation


-4 1,500 300 Retired
-3 1,500 300 300 Retired
-2 1,500 300 300 300 Retired
-1 1,500 300 300 300 300 Retired
0 1,500 300 300 300 300 300 Retired
1 1,500 500 400 300 200 100 Retired
2 1,500 500 400 300 200 100
3 1,500 500 400 300 200
4 1,500 500 400 300
5 1,500 500 400
6 1,500 500

Total Depreciation Charge on Tax Re-


turn. 1,500 1,700 1,800 1,800 1,700 1,500 1,500
B. Straight-Line Depreciation in Finan-
cial Reports .1,500 1,500 1,500 1,500 1,500 1,500 1,500

C. "Extra" Depreciation............. 0 200 300 300 200 0 0

N.B. All assets have a five-year service life and zero salvage value.

amounts of $150, $150, and $100, respec- tra" depreciation declines to a much
tively, would be made if tax rates are not smaller figure, but grows in every year
altered. Since tax and book depreciation thereafter.If the firm's rate of growth is
deductions are the same in every year after maintained, the "extra" depreciation not
year 4, the liability would remain on the only grows each year but grows by an in-
books in perpetuity unchanged from its creasingamount. If Table 2 were extended,
$500 amount. it would show that in year 20 "extra" de-
A somewhat more realistic model is in- preciation was $144 and by year 30 it
troduced if we consider a firm which grows would amount to $233.6
at a constant rate. In the first year of the If a liability for future taxes were recog-
period under consideration (year -4) it nized under these conditions, the balance
acquires $1,500 of depreciating assets. In- in the liability account would grow each
vestment in depreciating assets grows at a year. After a sufficiently long period, this
5% rate each year thereafter. The case is "liability" might well become one of the
further simplified by again assuming that major balance-sheet items.
all assets have a five-year service life and
zero salvage value. This firm also changes 6 The general formula for the calculation of the "ex-
tra" depreciation assuming a uniform service life (n), a
to the sum-of-the-years-digits method for constant rate of growth (r), and an initial investment of
tax purposes in year 1 and continues to use Xis:
straight-line depreciation for financial ac- Extra depreciation in year y
counting.
Table -2 indicates the results for the -(X(1+r) )
(n(n+1
steadily growing firm. During the transi-
? (X(1 r)v1 (-74 I- +)
tion period, tax depreciation exceeds book
depreciation by substantial amounts. At
the end of the transition period this "ex- + X(x1+rwvu (n-')n? -

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176 The Accounting Review
TABLE 2
DEPRECIATIONCHARGESOF A FIRMGROWINGAT A 5% RATE

Assets Depreciation Chargein Year:


Acquired Cost of Assets
In Year 0 1 2 3 4 5 6 7

A. Tax Return Depreciation


-4 1,400 300 Retired
-3 1,575 315 315 Retired
-2 1,654 331 331 331 Retired
-1 1, 736 347 347 347 347 Retired
0 1,823 365 365 365 365 365 Retired
1 1,914 638 510 383 255 128 Retired
2 2 ,010 670 536 402 268 134 Retired
3 2,110 703 563 422 281 141
4 2,216 739 591 443 295
5 2,327 776 621 465
6 2,443 814 651
7 2,565 855

Total Depreciation Charge on Tax Return. 1,658 1,996 2,223 2,334 2,324 2,185 2,293 2,407
B. Straight-Line Depreciation in Financial Re-
ports .1,658 1,740 1,827 1,919 2,015 2,115 2,221 2,332

C. "Extra" Depreciation .................... 0 256 396 415 309 70 72 75

N.B. All assets have a five-year service life and zero salvage value.

CRITERIA FOR RECOGNITION OF The crux of the matter then is whether the
EXPENSES AND LIABILITIES events in these cases have established the
Does a difference in the deduction for existence of a liability.
depreciation on the tax return as compared Concerning liabilities the statement
with the books require an accrual entry in says:
all cases, including of course the two ex- "The interests or equities of creditors (liabil-
amples of the previous section? If our ac- ities) are claims against the entity arising from
past activities or events which, in the usual case,
counting criteria for expense and liability require for their satisfaction the expenditure of
recognition were sufficiently precise and corporate resources.... The discharge of a liabil-
complete, we could measure this situation ity at a determinable date is normally required
against the rules and reach an easy an- by contract or intent of parties."8
swer. Unfortunately the criteria in this area Any future tax item arising from the
do not permit so easy an approach. cases of the previous section fails com-
The 1957 Revision of Accounting and pletely to meet these usual tests of a liabil-
Reporting Standards for Corporate Finan- ity. The Federal government recognizes
cial Statements may serve as a guide. It no "claim against the entity" in its record-
says with regard to expenses: keeping; "the expenditure of corporate re-
"Recognition of cost expiration [expense] is sources" will not be required,neither at a
based either on complete or partial decline in the "determinable date" nor at any other
usefulness of assets or the appearance of a liabil-
ity without a corresponding increase in assets....
time.
The issuance of product guarantees, notice of Professor Moonitz, in a sense, assumes
adverse court rulings, and similar events estab- the existence of a liability by saying that
lishing the existence- of liabilities call for the the tax effect producedin one year by dif-
recognition of cost expiration."' ferences in depreciation timing has "an
TirE ACCOUNTINGREVIEW, October, 1957, p. 541. 8 Ibid., p. 542.

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AcceleratedDepreciation and Taxes 177

unavoidable offsetting tax effect in some Depreciation Provisions of the Tax Law
other year." If the tax were based on in- Unaltered
come generated by individual assets, this The depreciation provisions of the tax
assumption might be justified. Since the code are a part of the law of -the land and
tax is based on taxable income of the en- the law may, of course, be altered by Con-
tity however, there need not be a future gress at any time. However, no substantial
effect for the going concern, as we have indication that Congress feels that the
seen, if the two basic criteria are met. present provisions are too generous and
The comparison with bond liabilities should therefore be altered has come to my
made by Moonitz seems entirely beside attention. In fact, there has been some con-
the point. The liability that is recognized tention that present provisions are not
in most bond issues is made up largely of generous enough and that the amount of
the discounted present value of required acceleration permitted should be increased.
future interest payments. In fact, in the All of the history of tax legislation indi-
example cited of a bond issue that is al- cates that once special rights9 are granted,
ways refunded (a perpetuity, in other it is very difficult and unusual for Congress
words) the present value of the future in- to withdraw them, especially if the return
terest payments is the measure of the en- to the former rules would result in a dou-
tire liability. If it were possible to issue bling-up of tax burdens during the years of
bonds on a perpetual basis at a zero in- return. Current discussions of impending
terest rate, would a liability exist? The tax legislation all make mention of possible
answer clearly would seem to be no, that alterations in tax rates (the Moonitz crite-
such a transaction is in the nature of a rion (a)), but do not hint at less generous
gift. That is precisely the effect produced depreciation methods.
for the going concern by accelerated tax It is this feature of permanence of the
depreciation. So long as the firm follows a depreciation provisions of the tax law and
regular investment policy, it will receive a their general applicability that distin-
"gift" of having its income tax payments guishes cases of the sort under considera-
permanently reduced. It may well be ar- tion from those arising under the 60-month
gued that a gift should not be permitted to amortization provisions of the Revenue
distort comparative operating results by Acts of 1940 and 1950. Under those acts,
reducing an expense, but the solution is to rapid amortization was permitted only for
treat income taxes as an income distribu- facilities for which certificates of necessity
tion rather than to recognize an expense were issued. Even though continuous in-
than simply does not exist. vestment was planned by the firm, there
THE PROBABILITY OF THE NECESSARY
could be no assurance that the new facili-
CONDITIONS BEING REALIZED
ties would qualify for certificates of
necessity. Consequently when depreciation
The preceding sections indicate that charges on the tax return exceeded those
there will be no liability for future taxes shown on the financial statements, an off-
for static or growing firms if depreciation setting tax effect in a future year or years
provisions of the tax laws remain un- was possible if the criteria cited by Moon-
changed (or become more generous) and a itz were likely to be met.10 Where acceler-
regular policy of investment in depreciat-
ing assets is maintained. How likely is it 9 If tax depreciation exceeds book depreciation, this
that these necessary conditions will be is an indication that the firm is enjoying a special right.
10Measurement of the effective present liability,
realized? though, would be a substantial task as the next section

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178 The Accounting Review
ated depreciationis available for all assets post war decade from 1947 through 1956.12
and is likely to remain so, this problem In only two years in that interval, 1949
does not arise. and 1954, did investment in assets subject
to depreciation fall below that of the pre-
Regular InvestmentPolicy ceding year. In both cases the decline was
The second criterion of a regular invest- less than 5% and was quickly recovered.
ment policy is more difficult to define and It would appear that firms in the aggregate
to realize. Since an infinite number of asset have met this criterion of regular or grow-
acquisition and service life combinations ing investment in capital assets rather
is possible, generalization as to what satisfactorily over the last decade.
policy of investment would insure that Growth of investment in the economy as
future years' taxes would not be in- a whole does not necessarily indicate
creased by current differencesbetween tax growth, or even maintenance, of invest-
and book depreciation is probably im- ment by all firms in the economy. Al-
possible. In almost all cases a pattern of though the vast majority of income-tax-
capital asset acquisitions in which each paying firms are probably at least main-
year's purchases are equal to or greater taining their level of monetary investment,
than those of the previous year would suf- two classes of exceptions to this general
fice."1 Relatively small declines in pur- tendency may be noted. They are firms
chases punctuating periods of moderate with a single, or preponderant, indivisible
growth would under normal circumstances asset and new firms.
be accommodated within the assumption Firms owning a single office building or
as well. apartment house or operating, a single
Since conventional accounting proce- mine are examples of the first class of ex-
dures and tax regulations both operate in ceptions. A constant stream of capital-
historical cost terms, the series of invest- goods investment by such firms is un-
ments is measured in monetary, not real, likely, and funds made available annually
terms. During a period of rising prices ful- by the earning of depreciation charges are
fillment of the necessary criterion is more frequently used to reduce bonded indebt-
likely since it does not require a firm to edness or are invested in securities. For
maintain a constant rate of acquisition of such firms, income of the entity and in-
productive capacity but merely of dollar come from a single asset are virtually the
investment. same. If they employ an accelerated de-
In recent years our economy has, of preciation method in their tax accounting
course, been characterized by substantial and straight-line depreciation in their
growth rather than merely a maintenance financial recordkeeping, recognition of a
of investment. Aggregate investment in liability for future taxes might be appro-
producers' durable goods has grown at an priate if satisfactory assumptions could be
average rate of over 6% per annum in the made about future profitability and future
tax rates. The nature of their individual
suggests. Anticipating the analysis there, consider the assets, however, would reduce the signifi-
case of an asset costing $100,000 with a twenty year life
depreciated over a sixty month period. Assume a 50% cance of the income-tax deferral for these
tax rate and that a 6% discount rate is appropriate. In firms. Office buildings and apartment
the first year, depreciation on the tax return is $20,000
and on the financial records is $5,000, producing a tax houses are long-lived assets and the "addi-
"loan" of $7,500. The loan will be repaid at the rate of
$500 a year starting at the end of year 6. The present
value of such a stream of payments is only $3,846. 12Data drawn from National Income (1954 Edition),
11 Even with this pattern, sufficient divergence in a supplement to the Survey of CurrentBusiness (Wash-
service lives of different years' acquisitions could pro- ington, 1954), pp. 162-165 and Survey of CurrentBusi-
duce small adverse effects in subsequent years. ness (Feb. 1957), p. 14.

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AcceleratedDepreciation and Taxes 179
tional" taxes would begin to be paid only adjustments would be material after the
in the second half of their lives and would discount factor is recognized.
be spread over that entire second-half When investment expenditures fluctuate
period. At any reasonable discount rate, erratically, a special problem is likely to
the present value of the taxes deferred in arise. One possibility for dealing with such
any one year would be relatively small. For a situation would be to divide the expendi-
example, if we assume a $1,000,000 build- tures for depreciable assets into continuing
ing with a 40-year life, a 50% tax rate per- and extraordinary portions, and to at-
sisting 40 years into the future, profitable tempt inter-period allocation only with re-
operations, and a 6% discount rate,. the spect to the extraordinary portion. The
tax saving in year 1 is $11,890 but the 1955 annual report of National Dairy Prod-
present value of the future liability is less ucts Corporation is an example of a divi-
than $2,000. In succeeding years the de- sion of plant expenditures for this purpose.
ferred tax liability would grow every year In the notes to the financial statements the
by the present value of that year's deferral following paragraph appears:
plus accrued interest at the assumed rate The Company, for income tax reporting only,
on the balance in the deferred liability ac- has adopted the declining balance method of
count at the start of the year. From year computing depreciation.... For all other pur-
13 on the interest accruals exceed the an- poses, including the financial statements, the
straight-line method is being continued. The re-
nual tax deferrals and it is well into the final duction in Federal and Canadian income taxes
third of the asset's life before the "future for the year 1955 arising from the additional de-
tax liability" begins to be reduced. Calcu- duction for depreciation so allowable for income
lation of the amounts in individual cases is tax reporting is estimated to be $2,850,000. Of
a long and tedious job, but the only other this amount, $2,500,000, representing the tax re-
duction applicable to regularly-recurring addi-
alternative if deferred taxes are to be rec- tions and replacements of machinery and equip-
ognized is to ignore the imputed interest ment, as estimated by the management, is
factor implicit in the situation. A failure to reflected as an addition to 1955 earnings through
recognize interest on liabilities that do not a reduction in the provision for 1955 Federal and
become payable for two decades or more Canadian taxes on income. The balance of
$350,000 of such tax reduction, which is at-
simply ignores the economic reality of the tributable to additional depreciation for tax re-
situation. There are too many cases al- porting on machinery and equipment additions in
ready in existence where accounting fails excess of regularly-recurring replacements, and
to recognize economic reality for us to add on buildings, has been deferred and is included in
another to the list. the "Provision for Federal and Canadian taxes
on income" in the accompanying balance sheet.
Newly organized firms will normally
make substantial investments in capital Firms with fluctuating annual expendi-
assets in their first year of existence. Un- tures are likely to be the major problem for
less expansion is exceptionally rapid in the the auditor. For a seasoned firm, replace-
following years, that first-year level of ex- ment and adaptation to changing technol-
penditure will not be maintained. If the ogy in a world of rising prices promise a
firm's profits make it worthwhile to claim reasonably high level of continuing invest-
accelerated depreciation on its tax return, ment. Occasional peaks of capital asset
but it shows only straight-line depreciation purchases, especially if their depreciation
in its accounting records, inter-period al- charges are spread over a long period, are
location of income taxes during this early unlikely in most cases to affect adversely
transitional period to regular investment income tax charges of future years in
may be warranted. It seems unlikely that amounts sufficient to justify current ac-
there are many cases of this type where the cruals.

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180 The Accounting Review

Financial statements are prepared for CONCLUSIONS


individual firms, not statistical averages, Many firms use an accelerated deprecia-
though, and the auditor must decide tion method for calculating the deprecia-
whether the firm he is considering falls into tion deduction to be made on the income
what is likely to be a relatively small tax return, but employ the straight-line
group of exceptions. In deciding he will depreciation method for calculating the
have to rely on evidence of past invest- depreciation expense figure for financial
ment policy, indications of long term plans statements. In considering the effect of this
and expressions of managerial intent rath- action on income tax expense and income
er than the more familiar types of ob- tax liability, attention must be centered on
jective verification. Assessment of future the taxpaying entity, the firm as a whole.
investment plans is somewhat more com- For a static or growing firm, current tax
plex than deciding whether profits will be savings from this source will not adversely
earned regularly in the future, but both affect income tax charges of future years.
require the same type of subjective deci- In fact, the growing firm can look forward
sion. Distasteful though it be, accountants to an ever-increasing annual tax saving
are likely to be faced by this type of prob- continuing year after year. Only a mori-
lem more often as efforts are made to make bund firm with declining investment in
income reporting more realistic. capital assets is likely to be faced by a sub-
On balance, it appears that the likelihood stantial deferred tax liability, and then
of the two primary criteria being realized, only if its dying years are profitable ones.
or of the secondary criterion of continuing Although the analysis indicates that a
profits not being met in those cases where liability for future taxes from this source
a constant level of investment is not antic- should be recognized only in rare cases,
ipated, is substantial; so substantial that disclosure of any difference between the
it would seem that inter-period allocation amount of depreciation claimed on the tax
of income taxes from this source should re- return and that shown in the income state-
quire explanation in the notes to the finan- ment is a desirable reporting practice and
cial statements. should be employed regularly.

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