<<Our current retention period and regulatory requirements state that these be retained for Fiscal Year + 4. <<

I think the answer comes down to asking the question about the following scenario:

The organization purchases a capital asset in 2015.  The asset which will be depreciated over 5 years, with an ending tax period of 2020.  The records associated with the purchase are disposed of per the current retention requirement in 2019 (FY + 4 years).  The IRS audits your 2018, 2019, and 2020 tax filings, providing notice in March, 2021 of their intention to disallow the depreciation deduction for the asset in each of the three years under review.

How do you intend to prove the cost basis of the depreciated item?

Additional questions to consider:
 - What if you are in an industry the depreciates materials for much longer periods?  
 - What if you dispose of the asset several years after its purchase, how do you prove the acquisition value necessary to accurately value capital gains?

Answer these and you will likely be able to determine whether your retention timeframe is sufficient.

Please note that forever is also not a good answer.  Forever is a really long time.

Bill Roach, CRM
Manager, Record Retention
______________________
MoneyGram International

Opinions are my own and not those of my employer or any other entity or individual.

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