Massachusetts · Verified 2026-08-17

Massachusetts bonus depreciation conformity for short-term rentals

Definitive 2026 breakdown of Massachusetts's treatment of federal IRC §168(k) 100% bonus depreciation for short-term rental investors. Verified against primary state DOR sources and cross-referenced to the DepreciMax state conformity dataset.

Direct answer: Massachusetts has explicitly disallowed §168(k) for PIT purposes since 2002 (TIR 02-11, 03-25) — full add-back with recovery over the property's normal life.

Massachusetts's §168(k) status

Massachusetts DOES NOT conform federal §168(k) bonus depreciation.
Conformity status
Decoupled
State add-back
100%
Top marginal rate
9%
Verified as of
2026-08-17
What this means for STR investors: Massachusetts requires a 100% add-back of §168(k) bonus depreciation for both PIT and corporate excise purposes. Massachusetts DOES allow the §179 expense election (unlike bonus). The 4% millionaires' surtax on income >$1M means high-income STR investors face an effective 9% top rate. On a $150,000 federal bonus deduction, a Massachusetts STR investor at 9% loses ~$13,500 in Year-1 state savings. Basis is adjusted for state purposes so disposition gain/loss is recalculated on the MA return.

Year-1 impact on Massachusetts STR investors — three scenarios

Scenario Federal §168(k) deduction Federal tax savings (32% bracket) Federal tax savings (37% bracket) Massachusetts state timing loss
Small STR — $50,000 federal deduction $50,000 $16,000 $18,500 $4,500
Typical STR — $150,000 federal deduction $150,000 $48,000 $55,500 $13,500
Luxury/multi-property — $300,000 federal deduction $300,000 $96,000 $111,000 $27,000

"Massachusetts state timing loss" = the Year-1 state tax savings foregone because of Massachusetts's 100% add-back. Deductions recover over the property's normal MACRS depreciation life on the state return — this is a timing hit, not a permanent loss. The federal deduction is unaffected.

Source: Mass. Gen. Laws ch. 62, §2(d)(1)(N); TIR 02-11; TIR 03-25
Primary source URL: https://www.mass.gov/technical-information-release/tir-03-25-depreciable-business-assets-modifications-for-decoupling-from-federal-bonus-depreciation
Verified: 2026-08-17

Massachusetts bonus depreciation — common questions

Does Massachusetts conform to federal bonus depreciation for short-term rentals?

Massachusetts does not conform federal §168(k) bonus depreciation. Massachusetts requires a 100% add-back of §168(k) bonus depreciation for both PIT and corporate excise purposes. Massachusetts DOES allow the §179 expense election (unlike bonus). The 4% millionaires' surtax on income >$1M means high-income STR investors face an effective 9% top rate. On a $150,000 federal bonus deduction, a Massachusetts STR investor at 9% loses ~$13,500 in Year-1 state savings. Basis is adjusted for state purposes so disposition gain/loss is recalculated on the MA return.

How much state tax does a Massachusetts STR investor lose in Year 1 because of non-conformity?

On a $150,000 federal §168(k) bonus depreciation deduction, a Massachusetts STR investor at the 9% top marginal rate loses $13,500 in Year-1 state tax savings due to the 100% add-back. The federal savings of about $48,000-$55,500 (at 32%-37% brackets) are unaffected and remain the dominant portion of the Year-1 tax benefit.

Can Massachusetts STR investors still benefit from §168(k) bonus depreciation?

Yes — federal §168(k) 100% bonus depreciation remains the largest single Year-1 tax benefit for STR investors, and it is unaffected by Massachusetts's state-level decoupling. The federal deduction still offsets W-2 income when the §469(c)(2) STR loophole applies (average guest stays ≤ 7 days + material participation). The Massachusetts add-back is a deferral, not a permanent loss — deductions recover over the property's normal MACRS life on the state return.