Client Profile

IndustryTrucking & Logistics (Regional Freight)
Annual Revenue$5,000,000
Entity TypeS-Corp (Operating) + Equipment Leasing LLC
StateTennessee
Key Metric42-truck fleet, $3.2M equipment basis, $680K annual fuel spend
Annual Tax Savings$118,000

The Problem

This regional freight company operated a fleet of 42 trucks and trailers generating $5 million in annual revenue. The fleet included Class 8 tractor-trailers, box trucks, and refrigerated units with a combined equipment basis of $3.2 million. The prior accountant was depreciating all vehicles on standard 5-year MACRS schedules without electing Section 179 immediate expensing on qualifying acquisitions and without tracking bonus depreciation eligibility on new versus used equipment.

The company was also spending approximately $680,000 annually on diesel fuel but had never claimed federal excise tax credits under IRC §6427 for off-highway use of fuel in auxiliary power units, refrigeration units, and yard equipment. Additionally, the owner's personal income from the S-Corp exceeded $750,000, but no retirement plan beyond a basic SIMPLE IRA had been established.

AE Tax Strategy

1. Fleet Depreciation Optimization Under IRC §179 and §168(k)

We restructured the fleet acquisition and disposition strategy to maximize depreciation deductions. All new truck acquisitions exceeding 6,000 pounds GVWR qualified for Section 179 immediate expensing up to the annual limit of $1,220,000. In the current year, eight new trucks totaling $1,840,000 were fully expensed under Section 179. We also implemented a 36-month fleet rotation cycle aligned with tax year planning to create recurring annual deduction events. Used vehicles acquired during the year qualified for bonus depreciation under IRC §168(k). Annual ongoing fleet depreciation savings: $58,000.

2. Federal Fuel Tax Credits Under IRC §6427

We conducted a comprehensive fuel use audit and identified $142,000 in annual diesel consumption that qualified for the federal excise tax credit under IRC §6427. Qualifying uses included refrigeration unit fuel ($68,000), auxiliary power unit operation during mandatory rest periods ($34,000), yard tractors and forklifts operating on private property ($26,000), and power take-off equipment ($14,000). At the current federal excise tax rate of $0.244 per gallon, the annual fuel tax credit totaled $34,700. We also filed amended returns for two open years, recovering an additional $62,000 in unclaimed credits. Annual ongoing fuel credit: $35,000.

3. Equipment Leasing Entity and Defined Benefit Plan Under IRC §162 and §401(a)

We established an equipment leasing LLC to hold the fleet and lease vehicles back to the operating S-Corp at fair market lease rates. The leasing LLC captured depreciation deductions at the individual level, offsetting the owner's pass-through income. We also replaced the SIMPLE IRA with a defined benefit pension plan under IRC §401(a), allowing the owner (age 54) to contribute $178,000 annually on an actuarially determined basis. The combined entity separation and retirement plan optimization produced annual tax savings of $25,000.

Annual Ongoing Tax Savings: $118,000 (plus $62,000 in amended return fuel credit recoveries)

Before & After Comparison

Tax CategoryBeforeAfterSavings
Fleet Depreciation (Section 179 + Bonus)$22,000$80,000$58,000
Federal Fuel Tax Credits (Annual)$0$35,000$35,000
Fuel Credits Amended Returns (One-Time)$0$62,000$62,000
Equipment Entity + DB Plan (Annual)$8,000$33,000$25,000
Total (Annual Ongoing)$30,000$148,000$118,000

Key Takeaways

  • Trucking companies with refrigeration units, APUs, yard equipment, and PTO devices should audit fuel consumption for IRC §6427 excise tax credits. Off-highway and non-propulsion fuel use generates credits of $0.244 per gallon.
  • Class 8 trucks and trailers over 6,000 lbs GVWR qualify for full Section 179 expensing. A structured fleet rotation cycle creates predictable annual deduction events that can be planned around income targets.
  • Equipment leasing entities allow fleet owners to capture depreciation at the individual level while creating deductible lease expenses at the operating company level.
  • Defined benefit plans allow owner-operators over age 50 to shelter $150,000 to $250,000 annually in tax-deferred retirement contributions, far exceeding the limits of 401(k) or SEP-IRA plans.