Casualty and Theft Loss Deduction: What Survived TCJA

Federally Declared Disasters Only • 10% AGI Floor • Business Loss Fully Deductible • Insurance Netting
IRC §165IRC §165(h)Treas. Reg. §1.165-7
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TCJA dramatically restricted the personal casualty and theft loss deduction. Before 2018, any sudden, unexpected loss from fire, storm, theft, or other casualty was potentially deductible. From 2018 through at least 2025, personal casualty losses are deductible only if they arise from a federally declared disaster under the Stafford Act. Business and income-producing property casualty losses are not subject to this restriction and remain fully deductible. This distinction - personal vs. business property - determines whether a loss is deductible at all.

2026 Rules at a Glance

Personal property (home, car, personal belongings): Deductible only if the loss occurs in a federally declared disaster area. Subject to $100 floor per event and 10% of AGI floor for the net loss. Must itemize. Insurance proceeds reduce the deductible loss dollar for dollar.

Business or income-producing property: Deductible under §165(a) without the federal disaster restriction. Fully deductible as an ordinary business expense. Not subject to the 10% AGI floor or $100 floor.

Theft: Same federal disaster restriction applies for personal property. Business theft fully deductible in the year of discovery.

The Federal Disaster Declaration Requirement

A federally declared disaster is a declaration by the President under the Robert T. Stafford Disaster Relief and Emergency Assistance Act. IRS.gov maintains a list of qualifying disaster declarations. Common qualifying events: hurricanes (Helene, Ian, Harvey), wildfires in California, flooding events with presidential declarations. Not qualifying: a tree falls on your car, your basement floods from a private pipe failure, your home is burglarized. The event must be in an area covered by a federal declaration.

Check IRS.gov for the specific declaration number and affected counties before claiming a deduction. The deduction is allowed only for taxpayers whose loss occurred in the declared disaster area. A hurricane that hits the Florida coast creates a deduction only for taxpayers whose property was in the specific counties listed in the declaration - not everyone in Florida.

Computing the Personal Casualty Deduction

For each casualty event: (1) Determine the lesser of adjusted basis or decrease in FMV. (2) Subtract any insurance reimbursement received or expected. (3) Apply the $100 floor per event. Sum all net casualty losses for the year, then apply the 10% of AGI floor - only the amount exceeding 10% of AGI is deductible. The remaining amount is an itemized deduction on Schedule A. If the taxpayer takes the standard deduction, the casualty deduction provides no benefit.

Business Casualty: Fully Deductible

A casualty loss on property used in a trade or business is deductible under §165(a) and (c)(1) without any of the TCJA restrictions. The loss equals the adjusted basis of the destroyed property minus any insurance proceeds. For partially destroyed business property, the loss is the decrease in FMV up to adjusted basis minus insurance. Business casualty losses flow through Schedule C (sole proprietors), Form 4684, or the partnership/corporate return. No federal disaster declaration required. No 10% AGI floor.

Authority: IRC §165(a) (general deduction for losses sustained during the taxable year; not compensated by insurance or otherwise); IRC §165(c) (limitations on losses of individuals - limited to losses in trade or business, transactions entered into for profit, and losses from fire/storm/shipwreck/theft/federally declared disaster); IRC §165(h) (limitation on personal casualty and theft losses - $100 floor per event; 10% of AGI floor on net casualty gains and losses; TCJA amendment adding federal disaster requirement effective 2018-2025 under §165(h)(5)); TCJA P.L. 115-97 §11044 (personal casualty loss restriction to federally declared disasters; effective for losses in tax years 2018 through 2025; sunset was 2025 but may be extended - verify for 2026); Treas. Reg. §1.165-7 (casualty losses - definition of casualty; decrease in FMV method vs. cost of repairs; documentation requirements; insurance netting); Treas. Reg. §1.165-8 (theft losses - discovery year rule; definition of theft under state law; documentation requirements); Robert T. Stafford Disaster Relief and Emergency Assistance Act, 42 U.S.C. §5121 (federal disaster declaration authority; presidential major disaster declaration required for personal casualty deduction); Form 4684 (Casualties and Thefts - computation of casualty loss; personal and business sections; insurance reimbursement netting; net operating loss carryover from disaster losses); IRS Publication 547 (Casualties, Disasters, and Thefts - comprehensive guide including disaster declaration list, computation examples, special rules for disaster losses).
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