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Tax strategy · Practices and device companies

Medical devices: planning for the practices that buy them and the companies that build them.

Imaging, lasers, surgical systems, CBCT scanners and dental chairs are major investments for a practice. Developing those devices is a major research investment for a manufacturer. Both sides have specific tax rules and credits we plan around.

Forms & standards
IRC § 179IRC § 168(k)IRC § 44IRC § 41IRC § 174AIRC § 1202

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

What we handle

For practices and for device companies

For medical, dental and veterinary practices, equipment is generally 5- or 7-year property eligible for section 179 (up to $2.5 million, phased out above $4 million) or 100% bonus depreciation for property acquired after January 19, 2025. The deduction starts when the equipment is placed in service, meaning installed and ready for its function, not when it is ordered or paid for. Financing and leasing choices affect who claims the deduction, and accessibility equipment may also qualify for the disabled access credit under section 44 for small practices.

For device manufacturers, design, prototyping and testing work commonly qualifies for the research credit under section 41, and domestic research costs can be deducted immediately under section 174A. The 2.3% medical device excise tax under section 4191 was repealed for sales after December 31, 2019. Founders and investors may exclude gain on qualified small business stock under section 1202, which was expanded for stock issued after July 4, 2025.

Speak with an advisor
  • Purchase or lease analysisAfter-tax cost comparison of buying, financing and leasing equipment.
  • Section 179 and bonus timingPlacing equipment in service before year end and choosing between the two methods.
  • Build-out and cost segregationSeparating equipment wiring, cabinetry and interior improvements in medical office space.
  • Disabled access creditCredit for small practices that buy accessibility equipment or modify facilities.
  • R&D credit for device makersDesign controls, verification and validation testing documented as qualified research.
  • Section 174A and 280CImmediate expensing of domestic research and the reduced credit election.
  • QSBS planningC corporation structure and holding periods for section 1202 exclusion.
  • State and property taxesVirginia business personal property tax on equipment and state conformity differences.

Where we help

Code sections and court cases

2014

Suder v. Commissioner, T.C. Memo. 2014-201

A telecommunications equipment maker won most of its R&D credit, including a large part of the CEO's wages, because its engineers' development work was well documented.

2019

Siemer Milling Co. v. Commissioner, T.C. Memo. 2019-37

The contrast: credits were denied when the company could not show a process of experimentation.

Statute

IRC § 4191 repeal

The medical device excise tax was repealed by the Further Consolidated Appropriations Act, 2020, for sales after 2019.

Regulation

Placed in service

Depreciation begins when an asset is ready and available for its assigned function. Equipment delivered but not installed by year end generally waits for the next year.

Our approach

How the engagement runs.

Plan

Purchases, timing, financing and entity structure.

Document

Invoices, installation dates and research records.

Claim

Depreciation, credits and elections on the return.

Defend

Support for IRS or state examinations.

Questions

Frequently asked

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

Can my practice deduct a new imaging system in the year we buy it?

Yes if it is placed in service that year, using section 179 or 100% bonus depreciation. Ordering or paying in December is not enough if installation happens in January.

Is it better to lease or buy medical equipment?

It depends on cash flow, financing rates and whether you can use the deduction. Under a true lease the lessor takes the depreciation and you deduct rent; under a financing lease you are treated as the owner.

Does the medical device tax still apply?

No. The 2.3% excise tax was repealed for sales after December 31, 2019.

Do FDA submissions and clinical testing count for the R&D credit?

Activities to resolve technical uncertainty in design, including verification and validation testing, often qualify. Purely regulatory paperwork generally does not.

Can founders of a device startup exclude gain on sale?

Possibly, under section 1202 if the company is a qualifying C corporation and the stock is held long enough. For stock issued after July 4, 2025, partial exclusions start at three years and the full exclusion at five.

Does Virginia allow the same deductions?

Virginia does not follow federal bonus depreciation, and localities tax business equipment as personal property.

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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