So an experienced CPA recently told me that essentially all costs incurred prior to placing a tenant are considered to be acquisition costs and get written off only as depreciation. Is this true? I'm sure he knows what he is talking about, but I wanted some second opinions. Are there any expenses that are directly tax deductible which are incurred prior to placing a tenant? Or are all expenses taken as depreciation? This includes closing costs? Interest on mortgage payments? Utility bills? All rehab expenses? Everything? 

Utilities are deductible, everything else will be depreciated.

@Chris Sullens 

Summary: You have  to capitalize work done but there is an exception for anything less than $2500

I think there can be two situations:

1) You convert your personal use home to rental:

You can deduct your ordinary and necessary expenses for managing, conserving, or maintaining rental property from the time you make it available for rent. Addition and improvement would be added to basis no matter if they are pre-rental or post-rental unless de minimis election of expensing $2500 is taken

2) You buy a new property for rental:

No matter if it is pre or post rental, the cost of any additions or improvements made before placing your property into service as a rental that has a useful life of more than 1 year is added to the basics like normal improvements, unless de minimis rule election is taken for items less than $2500.

This is a summary of the from IRS regulation:

“( (d) ) Acquired or produced tangible property—(1) Requirement to capitalize. Except as provided ….. and in § 1.263(a)-1(f) (providing a de minimis safe harbor election), a taxpayer must capitalize amounts paid to acquire or produce a unit of real or personal property”

See that "Except as provided ….. and in § 1.263(a)-1(f) (providing a de minimis safe harbor election)," exception, you can take de minimis safe harbor election.

e.g. Work performed prior to placing the property in service. In Year 1, M purchases a building for use as a business office. Prior to placing the building in service, M pays amounts to repair cement steps, refinish wood floors, patch holes in walls, and paint the interiors and exteriors of the building. In Year 2, M places the building in service and begins using the building as its business office ….Under paragraph (d)(1) of this section[Which is above], the amounts paid must be capitalized as amounts to acquire the building unit of property because they were for work performed prior to M's placing the building in service.

Similar to above, you do not have to capitalize everything: You can expense those work based on the de minimis rule. Taxpayers are limited to $2,500 per invoice or per item (as substantiated by the invoice).

Finally, After you make the house available for rent, you can deduct your ordinary and necessary expenses for managing, conserving, or maintaining rental property from the time you make it available for rent. 

Thanks @Ashish Acharya ! Regarding the de minimis rule, is that saying that any invoiced expense under $2500 can be deducted rather than capitalized? So, I had new flooring installed in this new rent house, but it cost me $2000. This is prior to any tenant being placed. Does that expense fall into the de minimis rule? What if I have several items like that and all together it's 12k worth of expenses? But each item is less than $2,500?

@Chris Sullens

Your CPA was not exactly correct.  All expenses incurred to make a property ready and available for service as a rental are capitalized.  There is no de minimis safe harbor here because the property is not yet in service as a rental.  

Once the property is ready and available for rent, you can expense repairs and start depreciation.  Ready and available for rent means that the property is officially "on the market" as a rental even though it may take some time to actually get a tenant under lease. So, amending your CPA's advice, all direct make-ready expenses incurred before the property is ready and available for service have to be capitalized.  

Originally posted by @Chris Sullens :

Thanks @Ashish Acharya! Regarding the de minimis rule, is that saying that any invoiced expense under $2500 can be deducted rather than capitalized? So, I had new flooring installed in this new rent house, but it cost me $2000. This is prior to any tenant being placed. Does that expense fall into the de minimis rule? What if I have several items like that and all together it's 12k worth of expenses? But each item is less than $2,500?

New flooring of 2000 can be expensed. 

If the invoice has multiple items, you look at the items separately. you need to factor into taxes for those items too. Meaning, all the expenses are added to make one unit/Item ready ( shipping cost, taxes, installation and those kinds of stuff). There can be multiple items per invoice but can be looked at separately. 

Talk to you CPA, he should know this.  

Originally posted by @Ashish Acharya :

Originally posted by @Chris Sullens:

Thanks @Ashish Acharya! Regarding the de minimis rule, is that saying that any invoiced expense under $2500 can be deducted rather than capitalized? So, I had new flooring installed in this new rent house, but it cost me $2000. This is prior to any tenant being placed. Does that expense fall into the de minimis rule? What if I have several items like that and all together it's 12k worth of expenses? But each item is less than $2,500?

New flooring of 2000 can be expensed. 

If the invoice has multiple items, you look at the items separately. you need to factor into taxes for those items too. Meaning, all the expenses are added to make one unit/Item ready ( shipping cost, taxes, installation and those kinds of stuff). There can be multiple items per invoice but can be looked at separately. 

Talk to you CPA, he should know this.  

 Ashish,  This is not correct.  What you are talking about are expenses that are incurred between tenants or during tenancy - essentially, after the property is placed in service.

For expenditures that are incurred before the property is placed in service, almost everything needs to be capitalized.  This includes labor and materials for repairs and improvements, interest on loans used for acquisition or repairs, property taxes, etc.  There are a few *possible* exceptions that have to do with services received currently vs services to be put into service later.  Some possibilities are:

1. HOA dues - if this is for current/ongoing maintenance of the property, then it's possible to expenses HOA dues right away.

2.  Utilities - if this is for current service to the property, then a case can be made for expensing utilities such as water and gas/electricity right away.

3.  Ongoing services - if you have to get the grass cut weekly during the remodel phase, then these ongoing services can also be expensed right away.  

4.  Services unrelated to the property.  If you are paying an accountant or lawyer for services unrelated to the actual property (such as bookkeeping or drawing up blank leases, etc), then that can be expensed right away.

5.  Other current items.  If you go to Starbucks to buy coffee for your work crews or grab sandwiches for them, then that can be immediately expensed.  

These items are usually small enough during the construction phase that it doesn't really make sense to separate them out, so if you choose to roll the first 3 into the basis, that is acceptable.  The second two examples should always be expensed and not added to basis.

Linda, I appreciate your feedback.  This is IRS regulation §1.263(a)-2 

[This section discusses what needs to be capitalized and also gives the example of the work done to the property prior to placing in the service. It also gives exceptions on what does not need to be capitalized. I have bolded it]

"(d) Acquired or produced tangible property.

(1) Requirement to capitalize. Except as provided in §1.162-3 (relating to materials and supplies) and in §1.263(a)-1(f) (providing a de minimis safe harbor election), a taxpayer must capitalize amounts paid to acquire or produce a unit of real or personal property (as determined under §1.263(a)-3(e)), including leasehold improvements, land and land improvements, buildings, machinery and equipment, and furniture and fixtures. Section 1.263(a)-3(f) provides the rules for determining whether amounts are for leasehold improvements. Amounts paid to acquire or produce a unit of real or personal property include the invoice price, transaction costs as determined under paragraph (f) of this section, and costs for work performed prior to the date that the unit of property is placed in service by the taxpayer (without regard to any applicable convention under section 168(d)). A taxpayer also must capitalize amounts paid to acquire real or personal property for resale.

Examples. The following examples illustrate the rules of this paragraph (d). Unless otherwise provided, assume that the taxpayer does not elect the de minimis safe harbor under §1.263(a)-1(f) and that the property is not acquired for resale under section 263A."

[It says "assume that taxpayer does not elect the de minimis", which implies that taxpayer can elect for all the examples listed ]

[One of the examples is:] 

"Example (10). Work performed prior to placing the property in service. In Year 1, M purchases a building for use as a business office. Prior to placing the building in service, M pays amounts to repair cement steps, refinish wood floors, patch holes in walls, and paint the interiors and exteriors of the building. In Year 2, M places the building in service and begins using the building as its business office. Assume that the work that M performs does not constitute an improvement to the building or its structural components under §1.263(a)-3. Under §1.263-3(e)(2)(i), the building and its structural components is a single unit of property. Under paragraph (d)(1) of this section, the amounts paid must be capitalized as amounts to acquire the building unit of property because they were for work performed prior to M's placing the building in service."

[ As mention above, taxpayer could have elected to expense under de minimis because example assumes taxpayer didnt]

[ Also , if you look at the de minimis code below, it says specifically do not capitalize under sec 1.263(a)-2, which is above regulation that says you need to capitalize with exception of de minimis if you elect the de minimis.] 

"(f) De minimis safe harbor election.

(1) In general. Except as otherwise provided in paragraph (f)(2) of this section, a taxpayer electing to apply the de minimis safe harbor under this paragraph (f) may not capitalize under §1.263(a)-2(d)(1)" 

I hope that makes sense. Always open for your interpretation. Let me know.  thanks 

I have to agree with Linda. 

I think what it comes down to is more the intent of the property for business use. If it wasn't ready to be used yet to generate income (which it wasn't since you were making renovations to make it rent able) then it is not technically in service yet. So you can't deduct expenses since it's not yet an operational business. 

@Steven Hamilton II How do you interpret the reg provided above? 

Originally posted by @Natalie Kolodij :

I have to agree with Linda. 

I think what it comes down to is more the intent of the property for business use. If it wasn't ready to be used yet to generate income (which it wasn't since you were making renovations to make it rent able) then it is not technically in service yet. So you can't deduct expenses since it's not yet an operational business. 

@Steven Hamilton II How do you interpret the reg provided above? 

 I think he bought the property to rent. The capitalization rules kick in as soon as he purchases it. On the pre- rental expenses for his rental property, please see if you agree with what I wrote above. 

@Ashish Acharya ,

Before Jan 1, 2016 when the newest de minimis safe harbor rules became effective, we had to make a subjective determinination whether each tangible property cost was a repair or an improvement.  For property already in service, the de minimis safe harbor at the time allowed us to expense some inexpensive tangible property improvements if the total cost was $500 or less.  All repairs needed to make a property ready and available for service were deemed to be improvements and had to be capitalized.   Let's call these pre-2016 rules the "general rules." 

Beginning with tax year 2016, new de minimis safe harbor rules increased the qualifying inexpensive tangible property improvement  cost from $500 to $2500 per invoice, or per item if several items on the invoice were itemized.  The rules also required us to make a retroactive election for the entire tax year if we wanted to use the new §1.263 safe harbor. That is, in 2017 when I prepared my 2016 tax returns, If I wanted to use the new de minimis safe harbor rules, I had to attach a statement to my tax return affirming the §1.263 election and submit it with my 2016 tax return.  

If I did not choose the new §1.263 de minimis safe harbor election,  the old general rules applied.  If I did choose the election , then I had to expense every inexpensive tangible property improvement that qualified.  I did not have the option to choose expensing some small cost improvements and capitalizing others.  

Just how I see it.

Originally posted by @Dave Toelkes :

@Ashish Acharya,

Before Jan 1, 2016 when the newest de minimis safe harbor rules became effective, we had to make a subjective determinination whether each tangible property cost was a repair or an improvement.  For property already in service, the de minimis safe harbor at the time allowed us to expense some inexpensive tangible property improvements if the total cost was $500 or less.  All repairs needed to make a property ready and available for service were deemed to be improvements and had to be capitalized.   Let's call these pre-2016 rules the "general rules." 

Beginning with tax year 2016, new de minimis safe harbor rules increased the qualifying inexpensive tangible property improvement  cost from $500 to $2500 per invoice, or per item if several items on the invoice were itemized.  The rules also required us to make a retroactive election for the entire tax year if we wanted to use the new §1.263 safe harbor. That is, in 2017 when I prepared my 2016 tax returns, If I wanted to use the new de minimis safe harbor rules, I had to attach a statement to my tax return affirming the §1.263 election and submit it with my 2016 tax return.  

If I did not choose the new §1.263 de minimis safe harbor election,  the old general rules applied.  If I did choose the election , then I had to expense every inexpensive tangible property improvement that qualified.  I did not have the option to choose expensing some small cost improvements and capitalizing others.  

Just how I see it.

Dave, you are referring to the property that is already placed in service and the de minimis election is valid in that situation. The question here was about the property that is bought and work done before placing the property in service. 

Originally posted by @Ashish Acharya :

Originally posted by @Natalie Kolodij:

I have to agree with Linda. 

I think what it comes down to is more the intent of the property for business use. If it wasn't ready to be used yet to generate income (which it wasn't since you were making renovations to make it rent able) then it is not technically in service yet. So you can't deduct expenses since it's not yet an operational business. 

@Steven Hamilton II How do you interpret the reg provided above? 

 I think he bought the property to rent. The capitalization rules kick in as soon as he purchases it. On the pre- rental expenses for his rental property, please see if you agree with what I wrote above. 

No - don't agree in the slightest.  You may want to read up on basis calculations to prepare an asset for service.  If an asset is not ready for service, then costs to make it ready for service are capitalized.  This is one of those times where GAAP agrees with tax, so you can find this in most Intermediate Accounting textbooks.  Tax regulations don't go into it too much because they just tend to state "basis of asset" - the IRS doesn't get into telling you how to calculate basis too much, so you'll have to fall back on GAAP for that.

That's for the answers guys. As a non-CPA, what I'm taking away front this is: 1. I probably have to capitalize most of my expenses prior to making the house available to rent. I really wish I had known this upfront. That detail seems to escaped most my if reading about investing, most which leads one to believe that many expenses are immediacy deductible. 2. I need to find a CPA who really knows their stuff and is experienced with real estate investors!

@Chris Sullens  

@Linda Weygant has been in your corner providing excellent, accurate information throughout this post....I would give her a call if you're looking for a real estate CPA who knows their stuff :) 

@Natalie Kolodij , you know I really hadn't even considered that I might want to use a CPA who isn't local to me. That's something I guess I should consider. Thanks!

@Linda Weygant We are on the same page on the calculation of the basis, but when the property is acquired to be placed in for the service, the question is can you still take the de minimis election to deduct some expenses as opposed to capitalizing it.

If you read what I cited above, it says you can. It's a Regulation. If you don't agree with the guidance I cited, may be you can look at this federal register that says the additional cost that can be elected under de minimis is the work performed before placing the property in service.

https://www.federalregister.gov/documents/2013/09/19/2013-21756/guidance-regarding-deduction-and-capitalization-of-expenditures-related-to-tangible-property

“The final regulations adopt the commenters' suggestions, in part, and clarify the treatment under the de minimis safe harbor of transaction costs and other additional costs of acquiring and producing property subject to the safe harbor…….The final regulations also clarify that additional costs consist of the transaction costs (that is, the facilitative costs under § 1.263(a)-2(f)) of acquiring or producing the property and the costs under § 1.263(a)-2(d) for work performed prior to the date that the unit of tangible property is placed in service.”

It says additional cost includes work performed prior to the date that the unit of tangible property is placed in service.

Well that was a metric crapton of reading, but here are the nuggets I pulled out of it:  (Emphasis Mine as bold and underline)

In the link you provided, I could find nothing to back up your assertion, but found the following sections that back up mine.  Since what you linked contained almost 150 pages of information, I didn't read the whole thing word for word.  Instead, I did a couple of searches for key words and phrases (such as "prior to" and "in service" and "de minimus" and the below is what I found.

Please copy/paste the relevant sections that support a taxpayer's ability to claim a de minimus deduction for assets BEFORE they are placed into service.  I certainly couldn't find anything.  If it's true, then it's awesome and will make lots of people happy, but it would fly in the face of most other IRS Tax Code and conventions.

Work performed prior to placing the property in service. In Year 1, M purchases a building for use as a business office. Prior to placing the building in service, M pays amounts to repair cement steps, refinish wood floors, patch holes in walls, and paint the interiors and exteriors of the building. In Year 2, M places the building in service and begins using the building as its business office. Assume that the work that M performs does not constitute an improvement to the building or its structural components under § 1.263(a)-3. Under § 1.263-3(e)(2)(i), the building and its structural components is a single unit of property. Under paragraph (d)(1) of this section, the amounts paid must be capitalized as amounts to acquire the building unit of property because they were for work performed prior to M's placing the building in service.

Work performed prior to placing the property in service. In January Year 1, N purchases a new machine for use in an existing production line of its manufacturing business. Assume that the machine is a unit of property under § 1.263(a)-3(e) and is not a material or supply under § 1.162-3. N pays amounts to install the machine, and after the machine is installed, N pays amounts to perform a critical test on the machine to ensure that it will operate in accordance with quality standards. On November 1, Year 1, the critical test is complete, and N places the machine in service on the production line. N pays amounts to perform periodic quality control testing after the machine is placed in service. Under paragraph (d)(1) of this section, the amounts paid for the installation and the critical test performed before the machine is placed in service must be capitalized by N as amounts to acquire the machine. However, amounts paid for periodic quality control testing after N placed the machine in service are not required to be capitalized as amounts paid to acquire the machine.

V. Amounts Paid To Acquire or Produce Tangible Property Under § 1.263(a)-2

Section 1.263(a)-2T of the 2011 temporary regulations provided rules for applying section 263(a) to amounts paid to acquire or produce a unit of real or personal property. In general, the final regulations retain the rules from the 2011 temporary regulations, including general requirements to capitalize amounts paid to acquire or produce a unit of real or personal property...

Originally posted by @Linda Weygant :

Well that was a metric crapton of reading, but here are the nuggets I pulled out of it:  (Emphasis Mine as bold and underline)

In the link you provided, I could find nothing to back up your assertion, but found the following sections that back up mine.  Since what you linked contained almost 150 pages of information, I didn't read the whole thing word for word.  Instead, I did a couple of searches for key words and phrases (such as "prior to" and "in service" and "de minimus" and the below is what I found.

Please copy/paste the relevant sections that support a taxpayer's ability to claim a de minimus deduction for assets BEFORE they are placed into service.  I certainly couldn't find anything.  If it's true, then it's awesome and will make lots of people happy, but it would fly in the face of most other IRS Tax Code and conventions.

Example 10.

Work performed prior to placing the property in service. In Year 1, M purchases a building for use as a business office. Prior to placing the building in service, M pays amounts to repair cement steps, refinish wood floors, patch holes in walls, and paint the interiors and exteriors of the building. In Year 2, M places the building in service and begins using the building as its business office. Assume that the work that M performs does not constitute an improvement to the building or its structural components under § 1.263(a)-3. Under § 1.263-3(e)(2)(i), the building and its structural components is a single unit of property. Under paragraph (d)(1) of this section, the amounts paid must be capitalized as amounts to acquire the building unit of property because they were for work performed prior to M's placing the building in service.

Example 11.

Work performed prior to placing the property in service. In January Year 1, N purchases a new machine for use in an existing production line of its manufacturing business. Assume that the machine is a unit of property under § 1.263(a)-3(e) and is not a material or supply under § 1.162-3. N pays amounts to install the machine, and after the machine is installed, N pays amounts to perform a critical test on the machine to ensure that it will operate in accordance with quality standards. On November 1, Year 1, the critical test is complete, and N places the machine in service on the production line. N pays amounts to perform periodic quality control testing after the machine is placed in service. Under paragraph (d)(1) of this section, the amounts paid for the installation and the critical test performed before the machine is placed in service must be capitalized by N as amounts to acquire the machine. However, amounts paid for periodic quality control testing after N placed the machine in service are not required to be capitalized as amounts paid to acquire the machine.

V. Amounts Paid To Acquire or Produce Tangible Property Under § 1.263(a)-2

Section 1.263(a)-2T of the 2011 temporary regulations provided rules for applying section 263(a) to amounts paid to acquire or produce a unit of real or personal property. In general, the final regulations retain the rules from the 2011 temporary regulations, including general requirements to capitalize amounts paid to acquire or produce a unit of real or personal property...

 
Linda, I'm a CPA though not specifically a tax accountant. You either didn't notice or chose to ignore the best point @Ashish made, which is that the rule and examples you are quoting in your argument don't apply when you elect the de minimus safe harbor. Reg 1.263(a)-2 specifically says,

(d) Acquired or produced tangible property -

(1) Requirement to capitalize. Except as provided in § 1.162-3 (relating to materials and supplies) and in § 1.263(a)-1(f) (providing a de minimis safe harbor election), a taxpayer must capitalize amounts paid to acquire or produce a unit of real or personal property

Then it goes on to list your previously mentioned Examples 10 and 11.... the logic is pretty obvious that the de minimis exception supersedes the requirements in those examples.

How can you argue against that?

Originally posted by @Jake Moran :

Originally posted by @Linda Weygant:

Well that was a metric crapton of reading, but here are the nuggets I pulled out of it:  (Emphasis Mine as bold and underline)

In the link you provided, I could find nothing to back up your assertion, but found the following sections that back up mine.  Since what you linked contained almost 150 pages of information, I didn't read the whole thing word for word.  Instead, I did a couple of searches for key words and phrases (such as "prior to" and "in service" and "de minimus" and the below is what I found.

Please copy/paste the relevant sections that support a taxpayer's ability to claim a de minimus deduction for assets BEFORE they are placed into service.  I certainly couldn't find anything.  If it's true, then it's awesome and will make lots of people happy, but it would fly in the face of most other IRS Tax Code and conventions.

Example 10.

Work performed prior to placing the property in service. In Year 1, M purchases a building for use as a business office. Prior to placing the building in service, M pays amounts to repair cement steps, refinish wood floors, patch holes in walls, and paint the interiors and exteriors of the building. In Year 2, M places the building in service and begins using the building as its business office. Assume that the work that M performs does not constitute an improvement to the building or its structural components under § 1.263(a)-3. Under § 1.263-3(e)(2)(i), the building and its structural components is a single unit of property. Under paragraph (d)(1) of this section, the amounts paid must be capitalized as amounts to acquire the building unit of property because they were for work performed prior to M's placing the building in service.

Example 11.

Work performed prior to placing the property in service. In January Year 1, N purchases a new machine for use in an existing production line of its manufacturing business. Assume that the machine is a unit of property under § 1.263(a)-3(e) and is not a material or supply under § 1.162-3. N pays amounts to install the machine, and after the machine is installed, N pays amounts to perform a critical test on the machine to ensure that it will operate in accordance with quality standards. On November 1, Year 1, the critical test is complete, and N places the machine in service on the production line. N pays amounts to perform periodic quality control testing after the machine is placed in service. Under paragraph (d)(1) of this section, the amounts paid for the installation and the critical test performed before the machine is placed in service must be capitalized by N as amounts to acquire the machine. However, amounts paid for periodic quality control testing after N placed the machine in service are not required to be capitalized as amounts paid to acquire the machine.

V. Amounts Paid To Acquire or Produce Tangible Property Under § 1.263(a)-2

Section 1.263(a)-2T of the 2011 temporary regulations provided rules for applying section 263(a) to amounts paid to acquire or produce a unit of real or personal property. In general, the final regulations retain the rules from the 2011 temporary regulations, including general requirements to capitalize amounts paid to acquire or produce a unit of real or personal property...

 
Linda, I'm a CPA though not specifically a tax accountant. You either didn't notice or chose to ignore the best point @Ashish made, which is that the rule and examples you are quoting in your argument don't apply when you elect the de minimus safe harbor. Reg 1.263(a)-2 specifically says,

(d) Acquired or produced tangible property -

(1) Requirement to capitalize. Except as provided in § 1.162-3 (relating to materials and supplies) and in § 1.263(a)-1(f) (providing a de minimis safe harbor election), a taxpayer must capitalize amounts paid to acquire or produce a unit of real or personal property

Then it goes on to list your previously mentioned Examples 10 and 11.... the logic is pretty obvious that the de minimis exception supersedes the requirements in those examples.

How can you argue against that?

 Because DeMinimis Safe Harbor applies to repairs/improvements made AFTER the property is placed in service.  The discussion above (from three years ago - nice zombie thread - is regarding expenses incurred prior to the property placed in service.

Originally posted by @Linda Weygant :

 Because DeMinimis Safe Harbor applies to repairs/improvements made AFTER the property is placed in service.  The discussion above (from three years ago - nice zombie thread - is regarding expenses incurred prior to the property placed in service.

Where is there language that says the de minimis only applies to items AFTER placed in service?

Originally posted by @Jake Moran :

Originally posted by @Linda Weygant:

 Because DeMinimis Safe Harbor applies to repairs/improvements made AFTER the property is placed in service.  The discussion above (from three years ago - nice zombie thread - is regarding expenses incurred prior to the property placed in service.

Where is there language that says the de minimis only applies to items AFTER placed in service?

It related to the tax code treatment of an asset. 

The IRS considers an assets cost ALL costs incurred to make it do it's job. 

If you buy a machine for a warehouse you include the purchase, delivery, programming, ect costs. ALL in the cost. 

Same with a rental- all costs needed to make it ready for it's use are part of the cost. 

https://www.irs.gov/publications/p551

The deminimus pertains to a business costs but the business isn't open/ asset isn't in service with a rental until it's ready and available. 

Natalie is entirely correct.

@Ashish Acharya Since your thread got resurrected from 3 years ago. 

Do you still hold to the opinion that you can utilize the deminimus safe harbor BEFORE an asset is in service? 

Originally posted by @Jake Moran :

Originally posted by @Linda Weygant:

 Because DeMinimis Safe Harbor applies to repairs/improvements made AFTER the property is placed in service.  The discussion above (from three years ago - nice zombie thread - is regarding expenses incurred prior to the property placed in service.

Where is there language that says the de minimis only applies to items AFTER placed in service?

 Everything related to my position on this was already said above.  Nothing has changed.