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7.1 Introduction
Depreciation, depletion, and amortization are means of recovering in
before-tax dollars your investment in certain types of property used in your
trade or business, or held for the production of income. The basis upon
which depreciation, depletion, and amortization are calculated is normilly
the cost of the property, although property acquired as a gift, or in other
manners, may have a basis other than cost. The cost of buildings, machin-
ery, equipment, and trucks are examples of business property costs that may
be recovered by depreciation over the useful life of the asset. Acquisition
costs and lease bonus costs paid for mineral rights for natural resouries
such as oil and gas, minerals, and standing timber are examples of invest-
ment property costs that may be recovered by depletion. Numerous other
business costs such as the cost of acquiring a business lease, research and
development expenses, trademark expenses, and pollution control equip-
ment costs may be recovered by amortization. Depreciation, depletion, and
amortization all achieve essentially the same thing, that is, recovery of the
cost or other basis of investments in before-tax dollars through allowable
tax deductions over a specified period of time or over the useful life of the
investment. If depreciable property is sold, all or a portion of any extra
depreciation claimed in prior years may have to be recaptured as taxable
income. This concept is addressed in Chapter 8.
Figure 7-1 shows that the only difference between before-tax cash flow
and after-tax cash flow is state and federal income tax. To calculate income
tax, you must properly calculate taxable income. This requires reducing rev-
326
Chapter 7: Depreciation, Depletion, Amoi'iization, and Cash Flow 327
Alternatively, in accordance with the left column of Figure 7-1, the same
after-tax cash flow results may be obtained from calculating revenue minus
lll out-of-pocket expenditures.
Cash flow represents revenue or savings minus all cosfs, no matter w,hat
trocedrn'e you ase to calcttlate it. Therefore, for any operating period, after-
.ax cash flow is the after-tax lrloney that is available to an investor (individ-
ral or corpol'ate) to invest in new projects, pay out in dividends, pay off old
lebt, or retain for future investment purposes. It is imperative that after-tax
:ash flow calculated as described here be the basis for the correct after-tax
rnalysis of all types of investments.
$24,000 for the same period. Further, capital costs totaling $29,000
for equipment are also expected to be incurred during the year. Cal.
ct.:late the anticipated project cash flow for next year.
Solution:
Before-Tax Time Diagram, C = Cost, I = lncome, L = Salvage
Therefore, using Equation 3-2, since initial cost (or negative cash
flow) equals {inal salvage (or positive cash flow) the aftertax ROR is
7.24/o cotTrpared to the before-tax ROR o' 12h; a significant differ-
ence. lt is important to account for income tax considerations.
operating cosrs that lnay be expensed include costs for direct labor,
i,tiirect labor, materials, parts and supplies used for product produced
and
sc'ld. only
cosrs associated rvith product actually .old nroy be
deducted.
This introduces the reader to the subject of working capital .rri.n
involves
drrllus tied up in prociuct inventory, spare parts inventory, accounts
receiv-
able, required cash on hancr, etc., that are not deductible
for tax purposes
until such items are actually used up or sold, as in the case of produci
and
spare parts inventory. A more complete discussion of working
capital and
the accounting methods that affect its value is presented in chapter g.
Some other common costs in the operating expense category
include utili-
ties, freight and containers, borrowed money interest paiJ, royatties,
sever-
ance taxes, sales taxes, ad valorem taxes and certain ixcise
taxes. The cal_
culation and determination of some of these later items is expandea
upon
in Section 7.9,
additional income alnount to the cost depletion basis for the property.
Recapture may be avoided by not expensing exploration charges but
instead, adding such charges to the cost depletion basis ofthe property.
7.4 Depreciation
The term depreciation is used in a number of different contexts. some of
the most common are:
7.5 Depreciationl{ethods
Depreciation of tangible properry placed in service after l9g6
is based on
using Modified Accelerared cost Recovery System (MACRS)
depreciation
for: (1) the applicable depreciation methoa, (z) ttre appticable recovery
period (depreciarion life), and (3) the applicable first y.ui^d.pr".iation
con_
vention. MACRS depreciation calculations relate to the
following three
depreciation methods:
1) Straight Line
2) Declining Balance
3) Declining Balance Switching to Straight Line
A fourth method used to a lesser extent for tax deduction purposes
but to
a greater extentfor pubric company sharehorder reporting purposes is:
4) Units of Production
The following secrions 7.5a through 7.5e ilrustrate the application
of
these different merhods. The MACRS depreciation method
is addressed in
section 7.5e. Prior to introducing depreciation methods,
several timing con-
ventions that affect the first year depreciation deduction
need to be
addressed.
336 Economic Evaluation and lnvestment Decision Methods
Under the curent u.S. tax law, there are three applicable conventions that
have an effect on the ailowable depreciation deducti_on in the first ye3r.
These conventions apply io itre MACRS merhod, the'straight iinu'lrrrA'C(S
method (which is straight line depreciation for the recovery period allowed
by N{ACRS depreciation) and the arrernative ACRS method
iwhich applies
longer depreciation lives for straight line depreciation of special categories
of assets such as foreign tangible property or tax exempt use or bond
financed property). The recovery period begins when an asset is placed in
service under the applicable first year deduction convention. The terms
recovery period and recovery property are tax terms meaning depreciation
period and depreciable property.
Depreciation
Yearsl :($10,000)(1 t1)(1t2) = $1,ooo
Years 2 to 5 : (910,000X1/5) = 92,000
Year 6 : (910,000)(1/s)(1t2) : $1,ooo
Cumulative Depreciation
= 910,000
Note that because of the harf-year one convention,
years to fully depreciate the asset. The six annual
it takes six
depreciation
deductions are related to cash frow carculations in
the next example.
Capital costs such as land and working capital are not depreciable under
the tax law cf the United States and virtually all other countries. Working
capital investments typically represent money tied up in raw material and
product sale accounts receil'able. Chapter 8, Section 8.10 gives a more
detailed explanation of working capital. Land and working capital invest-
ments are deducted for tax pulposes as lump sum deductioiis equal to the
original investment cost in the year of sale or disposal of the assets. These
deductions commonly are called "write-offs." Sale value, if any, from liqui-
dation of land or working capital assets is treated as income in the year that
a write-off is taken. Example 7-3b illustrates these considerations as a varia-
tion of Example 7-3a.
The term "book value" or "tax book value" often is used interchangeably
with "adjusted basis." The terms "diminishing balance,,and ,,written down
value" have interchangeable meaning with "adjusted basis,, in canada and
Australia. All these terms represent the remaining undepreciated value of a
depreciable asset.
200"/o D.B.
Year 200% D.B. Rate, (2/5) x Adjusted Basis = Depreciation
1 .40 x 1/2 10,000 2,000
2 .40 8,000 3,200
3 .40 4,800 1,920
4 .40 2,880 1,152
5 .40 1,729 691
6 1,037
Cumulative Depreciation After 5 years $8,963
Note that the adjusted basis is not fully depreciated in five years.
_
This is a problem with declining balance d'epreciation. lt literally takes
infinite years to fully depreciate a given adjusted basis with declining
balance depreciation. Switching from declining balance to straight
line depreciation enables an investor to fully depreciate an asset in
the depreciation life plus one year as shown in the next section.
342 Economic Evaluation and lnvestment Decision Methods
7 year property includes property with an ADR class life of l0 years but
less than l6 years. This class includes office furniture, fixtures, equipment
such as mining machinery and oil and gas producing equipment and gather-
Chapter 7: Depreciation, Depletion, Amortization, and Cash Flow
345
Table 7-1 identifies the depreciation method, ADR class lives and recov-
ery period (depreciation life) for each class ofrecovery property.
half-year convention in the first year. The rates ir] Table 7-3 are not vtlid for
personal property subject to the micl-quarter convention or lbl rcal property.
Under those cirbumstances, the reader will be required to make his or her
own depreciation calculations or refer to yeal one mid-quarter convention
rate tables published by the IRS and various accountiirg house companies.
or the combined equivalent of both oil and gas production using 6.000 cubic
feet of gas as equivalent to one barrel of crude oil. If independent producer
prr..duction exceeds these limits. percentage depletion may be taken on the
equivalent of 1,000 barrels per day of crude oil or 6,000,000 cubic feet of
naturai gas production prorated over total annual production.
ble by a means other than cost depletion because you still get percentage
depletion which is usually larger than cost depretion anyway. Integrated oil
and gas producers have lost this benefit since they are no longer eligible for
percentage depletion on revenue from oil and gas production. However, all
types of mining operations get the larger of allowed percentage or cost
depletion on mining mineral revenue.
Solution:
50,000 barrels
Year 1:Cost Depletion = ($1S0,000X
1,000,000 barrels
= 97,500
50,000 barrels
Year 2: Cost Depletion = (9150,000 - $7,500X
950,000 barrels
= $7,500
lf percentage depletion had been taken in year one, rather than
cost depletion, the cost depletion basis for year two would be the
year one basis minus year one percentage depletion. This is illus-
trated in Example 7-9.
7.7b PercentageDepletion
Percentage depletion is a specified percentage of gross income after roy-
alties front the sale of ruinerals removed from the mineral property during
tlle lax ),ear. Hovveve4 the deduction for depletion under this method catxnot
Chapter 7: Depreciation, Depietion, Amortization. and Cash Flow
353
Percentage
Mineral Deposits Depletion,To
Solution:
Year 1
Solution:
Since silver is a 15% depletion rate minerar whire read and zinc are
22'k depletion rate minerals, sales revenues must be prorated for
percent depletion calculation purposes.
Solution:
only 70% of corporate mine deveropment or integratcd producer
intangible drilling costs can be expensed in the yea"r
incurred, with
the other 307" amortized over 60 months, beginning
in tre month the
cost is incurred or praced on the tax books.-Therifore,
9700,000 of
the year 0 cost can be expensed in year 0. thirty percent'of
the cost,
$300,000, is deducted using straight rine amortization over 60
months, with the first year amortization deduction (year
0 in this anal_
ysis) prorated from the month the cost was incurred.
From the sev-
enth to twelfth month of year 0 is 6 months so a 6/60
amortization
deduction is taken in year 0. Arternativery, the year 0 deduction
courd
Chapter 7: Depreciation, Depletion, Amort,zation, and Cash Flow 359
Year AmortizationDeductions
0 (6/60x$300,000) = (6/12x1l5x$300,000) = 930,000
1-4 (12l60X$300,000) = (12t12X1l5)($300,000) = $60,000
5 (6/60X$300,000) = (6/12X1l5X$300,000) = 930,000
llol tax dcductibie by ttre lender nor is it taxable income to the borrorver. All
income from the propefiy including the value of production payments, is
taxable income to the owner of the property working interest and that owner
is entitled to the applicable mineral depletion allowance..,The..owner.of the
production payment is not entitled to depletion on that amount.
In the process of calculating mineral project cash flow, the first items
deducted from applicable mineral sale revenues are the royalty costs
because in most instances, royalty owners are allowed to take depletion on
royalty revenues. Therefore, the investors in mining or petroleum properties
only get to take percentage depletion (when applicable for oil and gas) on
the net revenue after royalties which in the oil industry is often referred to
as the 'net revenue interest.' Landowner royalties vary with different min-
eral industries. In oil and gas, thb standard royalty is 1/8 or l2.5va of the
gross value of the product extracted from the property and may include an
up fiont fee on a dollar per acre basis, this fee is sometimes referred to as a
lease bonus or rental and generally goes into the cost depletion basis for a
lease. An overriding royalty or caried interest is similar to a landowner's
royalty and is subject to the same percentage depletion considerations. par-
ticipating interests also previously defined as net revenue interests and
working interests may change over a project life, but they too represent an
economic interest in the property and are subject to applicable percentage
depletion considerations. on the other hand, percentage depletion is not
allorved for lease bonuses, advanced royalty payments, or any other amount
payable without regard to actual production of minerals. only cost deple-
tion is applicable in rhis situation.
A 'severance tax' is a state tax imposed on the severing of natural
resources from the land and is based on the value or quantity of production.
Severance taxes are also defined as mining taxes, excise tax or a net pro-
ceeds tax dependent upon each states unique wording. However, the tax is
alu'ays based on actual production or output value of either oil and gas or
rnining minerals and tirnber. Severance taxes usually are calculated on a flat
dollar per unit produced basis, or as a percentage of the value of the
resource extracted.
A property tax (or ad valorem tax) is levied by rhe appropriate taxing
authority on the value of a property. property taxes can be levied by differ-
ent cities, counties, states or school districts. property taxes can be levied
against either real or personai property. Real property is taxed in all states,
but many states do not tax personal property. Royalty recipients are also
subject to their portion of severance and ad r.,alorem taxes. Such taxes are
Cnapter 7: Depreciation, Deoletion, Amortization. anC Cash Flow
351
ofren paid in fuli by the producer u,ho then allocates rhe taxes to the appro_
p'ate parties such as royalty recipients, thereby reducing the royalty
income actually distributed.
Properly accountin-e for the detailed tax implications
of all the
resource property taxes, rol'alties, and production payments goes 'arious
well
beyond the objectives of this textbook. In all evaluation situations,
the
investor's tax position rnust be carefully considered with appropriate
tax
personnel or material to determine the rlsulting tax benefits
and liabilities
or obligations of each investor.
If other income exists against which to use deductions from new projects,
the investor realizes the tax benefits more quickly than when other income
does not exist and negative taxable income must be carried forward. The eco-
nomics of projects will always look better for investors who have other income
against which to use deductions when incurred, compared to an investor that
does not have other income. Tilx savings are inflows of money, and the faster
they are rcalized, the better project economics look. Therefore, it is very
important to analyze the economic potential of projects from the viewpoint oi
the financial situation of the investor. This is true in all industries and coun-
tries. It is incorrect to carry negative taxable income forward in an analysis if
other taxable income exists, and it also is incorrect to credit a project with tax
savings from negative taxable income in any year if the invesior is in a finan-
cial situation that requires carrying negative iaxable income forward.
In this text, examples and problems in chapter 7 are presented primarily
-from the viewpoint of investors who must carry negative taxable income
forward using "stand alone" economics described earlier in this section.
Chapter 8 illustrates analyses from both the viewpoints of ,,stand alone,, and
"expense" economics. chapters 9 and l0 emphasize analyses from
the
viewpoint of investors that have other income against which to use deduc-
tions, so the "expense" economic analysis financial assumption is empha-
sized. The next example illustrates carrying negative taxaLle income for-
ward using the "stand alone" financial assumption.
h
Chapter 7: Depreciation, Deplelion, Amortization, and Cash
Flow
Solution:
7.ll Summary
The following is a summary of the various expenditures addressed in this
Chapter and the most likely treatment for tax purposes in economic evaluations.
Common Stock For all investors, write off the original cost
basis against the sale of stock to determine the
gain or loss. For individuals, gain or loss may
be subject to long-term capital gain, see
Chapter 8 for more details.
Mineral rights acquisition, For all mineral investors, such expenditures
lease bonus and recaptured form the basis for cost depletion deductions.
exploration costs are the
adjusted basis for Cost Cost Depletion =
Depletion (Adj Basis)( Units Produced & Sold
Proven Reserves at Beginning of Yr
Percentage Depletion Basis There is no cost basis for percentage depletion.
When applicable, percentage depletion is based
on a percentage of net revenue (Gross Revenue
- Royalties) and may be subject to a 50Vo limit
in mining or a 100Vo limit for oil and gas.
368 Economic Evaluation and lnvestment Decision Methods
-
Amortization is much like shaight-line depreciation and is used
to deduct
the cost of intangible assets such as goodwill, copyrights, patent
acquisitions, etc.
Depreciation - is related to the cost of tangible assets including
both
personal and real property. The most common methods
include straight line,
declining balance and units of production. In the united states,
the fastest
form of depreciation is declining balance switching to straight line
when it
is advantageous to do so.
Straight Line: (Cost BasisXl/n)
Declining Balance: (Adjusred Basis)(1/n) up to (Adjusted Basis)(2/n)
'Adjusted Basis" is cost basis less ail depreciation previouiily
taken.
Declining Balance Switching to straight Line: Based on declining
balance
methodology, this approach switches back to the straighrrine
method
when a taxpayer can achieve an equal or rarger deductiJn
by switching.
This occurs when the fraction of (i/Remaining Life) is equar
to or
greater than the declining balance rate because with
straight line, the
rate is applied to the remaining cost basis. This is the approach
utilized
in the MACRS depreciation percentages in Table 7_3.
Units of Production:
(cost Basis)(units produced)/(units Available to be produced)
In the resource industries, the units produced are based on proven
units in
reserves or hours of service.
PROBLEMS
7'l Equipment (such as oil and gas producing equipment, mining machin-
ery- or certain general industry r'quipment) has been purchased and put
into service for a $2,000,000 cost. calculare the N{ACRS dep:eciarion
(20avo declining balance swirching to straight line), and straight line
depreciation per year, for a7 year depreciation life, u,ith the half year
I convention applicable for both methods, assuming the equipment is
put in service in year 1.
7-3 A company has acquired a vehicle and right rrucks costing $100,000 in
the first quarter of the tax year anc research equipment costing
s500,000 in the fourth quarter of the tax year, so the mid-quarter con-
vention is appropriate for depreciation calculations (more than 4ovc of
depreciable cost is in the last quarter). The assets qualify as 5 year life
depreciable property. compute the MACRS depreciation and straight
line depreciation for each year.
7-4 Depreciable residential rental real property has been purchased for
$800,000 and put into service during the third month of the taxpayer's
tax year. For the applicable 27.5 year depreciation life, determine the
annual allowable straight line depreciation deductions. Remember that
for real property, the first year depreciation is proportional to months
of service and subject to the mid- month convention in the month real
property is placed in service.
s
Chapter 7: Depreciation, Depletion. Amortization, and Cash Flow
371
7-11 Petroleum mineral rights have been acquired at time zero for a lease
bonus of $200.000. A well is projected to be drilled and complered ar
time zero for an intangible drilling cost (IDC) of $500,000 and tangi-
ble producing equipment cosring $400,000. The tangibre producing
equipment is depreciable over 7 years using modified ACRS deprecia-
tion starting in year one, rvith the half year convention. Gross oil
income is expected to be $700,000 in year one, $600,000 in year two,
$500,000 in year three. $400.000 in year four and $300,000 in year
five. Royalties total 15.\vo of gross revenues each year (for a net rev-
enue interest of 85.07o). operating costs are estimated to be $50,000
per year in each of years one through five. Depletable oil reserves are
estimated to be 200,000 barrels with 30.000 barrels produced in year
one, 27,000 barrels in year trvo, 24,000 in year three,21,000 barrels in
374 _Economic Evaluation and lnvestment Decision Methods
year four and 18,000 in year five. Assume no other income exists so
all negative taxable income will be carried forward and used against
project taxable income (stand alone economics). use a 4o.0vo t'ax rate
and calculate the cash flows for each of years 0 through 5. Deduct
write-off's on remaining tax book values at year 5, when a sale value
of $250,000 is received. Determine the project DCFROR for:
.
r
376 Economic Evaluation and lnvestment Decision Methods
ordinary income. Calculate the annual after-tax project cash flows and
determine the DCFROR and NPV for an investor desiring an escalated
dollar after-tax minimum rate of return of l2%o.
7-15 Using the data in problem 7-14 as the base case, consider the following:
A) Suppose this was a mineral project that required an additional time
zero expenditure of $5,000,000 for mine development subject to a
70/30 split with a 12 month amortization deduction taken begin-
ning in year 1. Further, assume the land acquisition cost was really
a mineral acquisition cost subject to the cost depletion basis and
therefore, deductible by cost depletion and a write-off on the
remaining tax book value in the final year. Previously identified
production is in tons and total proven reserves are estimated at
10,000,000 tons. The mineral produced is a l}Vo mineral for per-
centage depletion purposes upon which, the 50Vo limit on taxable
income before the deduction would apply. Assume the given
annual revenues are net of any applicable royalties. Calculate the
annual after-tax project cash flows and determine the DCFROR
and NPV for an investor desiring an escalated dollar after-tax min-
imum rate of return of 127o.
B) Suppose this v,,as an integrated oil and gas company considering an
oil & gas project that required an additional time zero expenditure
of $5,000,000 in petroleum intangible drilling costs, subject to a
70/30 split with a 12 month amortization deduction taken begin-
ning in year 1. Frrrther, assume the land acquisition cost was really
a lease bonus cost subject to the cost depletion basis and therefore,
deductible by cost depletion and a write-off on the remaining tax
book value in the final year. Assume given annual revenues are net
of all applicable royalties. Previously identified production units
are in barrels and total proven reserves are estimated at 10,000,000
bbls. Calculate the annual after-tax project cash flows and deter-
mine the DCFROR and NPV for an investor desiring an escalated
dollar after-tax minimum rate of return of 12Vo.
C) Suppose this was a non-integrated oil and gas company with exist-
ing production in excess of i,000 bpd. The company is consider-
ing this to be an oil & gas project that required an additional time
zero expenditure of $5,000,000 in petroleum intangible drilling
Chapter 7: Depreciation, Depletion, Amortization, and Cash Flow 377
costs. FLrrther, assurne the land acquisition cost was really a lease
bonus cosr subject to the cost depletion basis and therefore,
deductible by cost depletion and a tax book varue write-off in the
final year. Previously given revenue is assumed to be net of all
applicable royalties. Previously identifrecl production is in barrels
and total proven reserves are estimated at 10,000,000 bbls. calcu-
late the annual after-tax project cash flows and determine the
DCFROR and NPV for an investor desiring an escalated dollar
after-tax minimum rate of return of l2Vo.