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Hospitality · Hotel owners & franchisees

Hotel franchise owners: turn your property into a tax strategy.

Owning a branded hotel means franchise fees, brand-required renovations, lender reporting and a payroll full of tipped staff. It also creates some of the strongest tax planning available to any business owner. Our advisors work with owners of Marriott, Hilton, IHG, Hyatt, Choice and independent hotels.

Forms & standards
IRC § 168(k)Cost segregationTreas. Reg. § 1.469-1T(e)(3)IRC § 197Treas. Reg. § 1.263(a)-3IRC § 45B

Serving United States, Virginia, Washington, DC, Maryland.

What we handle

Why hotels are different

Franchised hotels carry costs most businesses never see: initial franchise and application fees, ongoing royalty, marketing and reservation fees, property improvement plans (PIPs) the brand requires on a renewal or sale, replacement reserves for furniture and fixtures, management company fees, and financial reporting to lenders and the franchisor. Each has its own tax treatment, and getting it right affects both cash flow and the next refinancing.

Hotels also qualify for unusually strong planning. Since the 2025 tax law, 100% bonus depreciation is permanent for qualifying property acquired and placed in service after January 19, 2025, and a cost segregation study can move a large part of a hotel's cost from 39-year building life into 5-, 7- and 15-year property. Because average guest stays are seven days or less, a hotel is generally not a rental activity under the passive loss rules, so an owner who materially participates may be able to use those deductions against other income.

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  • Cost segregation and 100% bonus depreciationIdentifying furniture, fixtures, equipment, electrical and plumbing serving equipment, site work and parking that can be written off in year one.
  • PIP and renovation planningSeparating deductible repairs from capital improvements, using partial disposition write-offs for replaced components, and qualified improvement property for interior work.
  • Franchise and brand feesInitial franchise fees generally amortized over 15 years; royalty, marketing, loyalty and reservation fees deducted as incurred.
  • Passive loss and material participationDocumenting owner hours so hotel losses are nonpassive where the facts support it, and planning around the excess business loss limit.
  • Interest and financingBusiness interest limits, the real property trade or business election and its effect on depreciation, and refinancing structure.
  • Tips and payrollTip reporting, the employer FICA tip credit under section 45B for food and beverage service, and payroll audits.
  • Occupancy, sales, BPOL and property taxesTransient occupancy and meals taxes, Virginia BPOL (hotels pay $0.23 per $100 in Loudoun and $0.26 in Fairfax), and business personal property tax on FF&E.
  • Acquisitions, audits and salesQuality of earnings for hotel purchases, audited financial statements for lenders, purchase price allocation and 1031 exchanges.

Where we help

Tax strategies we use most

Year one

Cost segregation at purchase or build

A cost segregation study combined with 100% bonus depreciation can create large first-year deductions on a new acquisition or development.

Look-back

Catch-up on hotels you already own

For hotels placed in service in earlier years, an accounting method change can claim missed depreciation in the current year without amending returns.

PIP

Write off what the brand makes you replace

When a PIP replaces carpets, case goods or HVAC, the remaining basis of the old components can often be deducted through a partial disposition.

7-day rule

Use hotel losses against other income

With short average stays, the hotel is tested under material participation instead of the rental rules, which can unlock losses for active owners.

Our approach

How the engagement runs.

Review

Franchise agreement, PIP, management agreement, fixed asset ledger and prior returns.

Model

Depreciation, cash tax and loan covenant impact of each strategy over five years.

Implement

Cost segregation, method changes, entity and payroll setup.

Report and defend

Returns, lender and franchisor reporting, and audit support.

Questions

Frequently asked

If your question isn't here, call (703) 880-8412 and you'll reach a person.

Is 100% bonus depreciation available for hotels in 2026?

Yes, for qualifying property. The 2025 tax law made 100% bonus depreciation permanent for property acquired and placed in service after January 19, 2025. The building shell itself is 39-year property, so a cost segregation study is what identifies the shorter-life components that qualify.

Can hotel losses offset my other income?

Possibly. Under Treas. Reg. section 1.469-1T(e)(3), an activity with an average customer stay of seven days or less is not a rental activity, so the loss is passive only if you do not materially participate. In Bailey v. Commissioner, T.C. Summary Op. 2011-22, the court noted that a short-stay inn is not rental real estate, which meant hours spent there did not count toward real estate professional status for the owner's other rentals. Planning has to fit how you actually run the hotel.

How are hotel franchise fees deducted?

Initial franchise and application fees are generally intangible costs amortized over 15 years. Ongoing royalty, marketing, loyalty and reservation system fees are generally deducted in the year incurred.

Are PIP renovation costs deductible?

Some are and some are not. Under the tangible property regulations, repairs and maintenance can be deducted while improvements are capitalized, but capitalized interior improvements may qualify as 15-year property eligible for bonus depreciation, and replaced components can often be written off.

What does a management company change?

If a third-party company runs daily operations, it is harder for an owner to show material participation, so passive loss planning needs careful documentation of the owner's own work.

Are you affiliated with Marriott or other brands?

No. VG CPA PC is an independent CPA firm. We advise owners of franchised and independent hotels across brands.

Latest updates

IRS & federal tax

All IRS & federal tax updates
Nov 5, 2026IRS & federal tax

IRS releases 2027 inflation adjustments (Rev. Proc. 2026-35)

For 2027 the joint-return standard deduction rises to $33,200, the estate tax basic exclusion to $15,480,000, the annual gift exclusion to $20,000 and the Section 179 expensing limit to $2,640,000. Our advisors recommend revisiting year-end gifting and equipment purchase plans with these figures in mind.

Source: IRS (IR-2026-133)

Our guidance

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