Internal Revenue Bulletin 2017-19 (PDF rendition): IRS Notices

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HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
INCOME TAX
Rev. Rul. 2017–11, page 1230.
Federal rates; adjusted federal rates; adjusted federal long-
term rate and the long-term exempt rate. For purposes of
sections 382, 642, 1274, 1288, 7872, and other sections of
the Code, tables set forth the rates for May 2017.
Rev. Proc. 2017–33, page 1236.
This revenue procedure provides guidance under the Protect-
ing Americans for Tax Hikes Act of 2015 (PATH Act) regarding
amendments to (i) expensing section 179 property, (ii) the
additional first year depreciation deduction under section
168(k), and (iii) the qualified Indian reservation property depre-
ciation provision under section 168(j).
EMPLOYEE PLANS
Notice 2017–27, page 1232.
This notice sets forth updates on the corporate bond monthly
yield curve, the corresponding spot segment rates for April
2017 used under § 417(e)(3)(D), the 24-month average seg-
ment rates applicable for April 2017, and the 30-year Treasury
rates. These rates reflect the application of § 430(h)(2)(C)(iv),
which was added by the Moving Ahead for Progress in the 21st
Century Act, Public Law 112–141 (MAP-21) and amended by
section 2003 of the Highway and Transportation Funding Act of
2014 (HATFA).
ADMINISTRATIVE
Notice 2017–28, page 1235.
Notice inviting public comment on recommendations for the
2017–2018 Priority Guidance Plan.
Finding Lists begin on page ii.
Bulletin No. 2017–19
May 8, 2017

The IRS Mission
Provide America’s taxpayers top-quality service by helping
them understand and meet their tax responsibilities and en-
force the law with integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument of
the Commissioner of Internal Revenue for announcing official
rulings and procedures of the Internal Revenue Service and for
publishing Treasury Decisions, Executive Orders, Tax Conven-
tions, legislation, court decisions, and other items of general
interest. It is published weekly.
It is the policy of the Service to publish in the Bulletin all
substantive rulings necessary to promote a uniform application
of the tax laws, including all rulings that supersede, revoke,
modify, or amend any of those previously published in the
Bulletin. All published rulings apply retroactively unless other-
wise indicated. Procedures relating solely to matters of internal
management are not published; however, statements of inter-
nal practices and procedures that affect the rights and duties
of taxpayers are published.
Revenue rulings represent the conclusions of the Service on
the application of the law to the pivotal facts stated in the
revenue ruling. In those based on positions taken in rulings to
taxpayers or technical advice to Service field offices, identify-
ing details and information of a confidential nature are deleted
to prevent unwarranted invasions of privacy and to comply with
statutory requirements.
Rulings and procedures reported in the Bulletin do not have the
force and effect of Treasury Department Regulations, but they
may be used as precedents. Unpublished rulings will not be
relied on, used, or cited as precedents by Service personnel in
the disposition of other cases. In applying published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned
against reaching the same conclusions in other cases unless
the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions of
the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A, Tax
Conventions and Other Related Items, and Subpart B, Legisla-
tion and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to these
subjects are contained in the other Parts and Subparts. Also
included in this part are Bank Secrecy Act Administrative Rul-
ings. Bank Secrecy Act Administrative Rulings are issued by
the Department of the Treasury’s Office of the Assistant Sec-
retary (Enforcement).
Part IV.—Items of General Interest.
This part includes notices of proposed rulemakings, disbar-
ment and suspension lists, and announcements.
The last Bulletin for each month includes a cumulative index for
the matters published during the preceding months. These
monthly indexes are cumulated on a semiannual basis, and are
published in the last Bulletin of each semiannual period.
The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
May 8, 2017Bulletin No. 2017–19

Part I. Rulings and Decisions Under the Internal Revenue Code
of 1986
Section 1274.—
Determination of Issue
Price in the Case of
Certain Debt Instruments
Issued for Property
(Also Sections 42, 280G, 382, 467, 468, 482, 483,
642, 1288, 7520, 7872.)
Rev. Rul. 2017–11
This revenue ruling provides various
prescribed rates for federal income tax
purposes for May 2017 (the current
month). Table 1 contains the short-term,
mid-term, and long-term applicable fed-
eral rates (AFR) for the current month for
purposes of section 1274(d) of the Internal
Revenue Code. Table 2 contains the short-
term, mid-term, and long-term adjusted
applicable federal rates (adjusted AFR)
for the current month for purposes of sec-
tion 1288(b). Table 3 sets forth the ad-
justed federal long-term rate and the long-
term tax-exempt rate described in section
382(f). Table 4 contains the appropriate
percentages for determining the low-
income housing credit described in sec-
tion 42(b)(1) for buildings placed in ser-
vice during the current month. However,
under section 42(b)(2), the applicable per-
centage for non-federally subsidized new
buildings placed in service after July 30,
2008, shall not be less than 9%. Finally,
Table 5 contains the federal rate for de-
termining the present value of an annuity,
an interest for life or for a term of years, or
a remainder or a reversionary interest for
purposes of section 7520.
REV. RUL. 2017–11 TABLE 1
Applicable Federal Rates (AFR) for May 2017
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term
AFR1.15%1.15%1.15%1.15%
110% AFR1.27%1.27%1.27%1.27%
120% AFR1.38%1.38%1.38%1.38%
130% AFR1.51%1.50%1.50%1.50%
Mid-term
AFR2.04%2.03%2.02%2.02%
110% AFR2.24%2.23%2.22%2.22%
120% AFR2.45%2.44%2.43%2.43%
130% AFR2.66%2.64%2.63%2.63%
150% AFR3.07%3.05%3.04%3.03%
175% AFR3.58%3.55%3.53%3.52%
Long-term
AFR2.75%2.73%2.72%2.71%
110% AFR3.02%3.00%2.99%2.98%
120% AFR3.31%3.28%3.27%3.26%
130% AFR3.58%3.55%3.53%3.52%
REV. RUL. 2017–11 TABLE 2
Adjusted AFR for May 2017
Period for Compounding
AnnualSemiannualQuarterlyMonthly
Short-term adjusted AFR.86%.86%.86%.86%
Mid-term adjusted AFR1.52%1.51%1.51%1.51%
Long-term adjusted AFR2.04%2.03%2.02%2.02%
May 8, 2017Bulletin No. 2017–19
1230

REV. RUL. 2017–11 TABLE 3
Rates Under Section 382 for May 2017
Adjusted federal long-term rate for the current month2.04%
Long-term tax-exempt rate for ownership changes during the current month (the highest of the
adjusted federal long-term rates for the current month and the prior two months.)
2.09%
REV. RUL. 2017–11 TABLE 4
Appropriate Percentages Under Section 42(b)(1) for May 2017
Note: Under section 42(b)(2), the applicable percentage for non-federally subsidized new
buildings placed in service after July 30, 2008, shall not be less than 9%.
Appropriate percentage for the 70% present value low-income housing credit7.55%
Appropriate percentage for the 30% present value low-income housing credit3.24%
REV. RUL. 2017–11 TABLE 5
Rate Under Section 7520 for May 2017
Applicable federal rate for determining the present value of an annuity, an interest for
life or a term of years, or a remainder or reversionary interest
2.4%
Section 42.—Low-Income
Housing Credit
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of May
2017. See Rev. Rul. 2017-11, page 1230.
Section 280G.—Golden
Parachute Payments
Federal short-term, mid-term, and long-term
rates are set forth for the month of May 2017. See
Rev. Rul. 2017-11, page 1230.
Section 382.—Limitation on
Net Operating Loss
Carryforwards and Certain
Built-In Losses Following
Ownership Change
The adjusted applicable federal long-term rate
is set forth for the month of May 2017. See Rev.
Rul. 2017-11, page 1230.
Section 467.—Certain
Payments for the Use of
Property or Services
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of May
2017. See Rev. Rul. 2017-11, page 1230.
Section 468.—Special Rules
for Mining and Solid Waste
Reclamation and Closing
Costs
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of May
2017. See Rev. Rul. 2017-11, page 1230.
Section 482.—Allocation of
Income and Deductions
Among Taxpayers
Federal short-term, mid-term, and long-term
rates are set forth for the month of May 2017. See
Rev. Rul. 2017-11, page 1230.
Section 483.—Interest on
Certain Deferred Payments
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of May
2017. See Rev. Rul. 2017-11, page 1230.
Section 642.—Special Rules
for Credits and Deductions
Federal short-term, mid-term, and long-term
rates are set forth for the month of May 2017. See
Rev. Rul. 2017-11, page 1230.
Section 1288.—Treatment
of Original Issue Discount
on Tax-Exempt Obligations
The adjusted applicable federal short-term, mid-
term, and long-term rates are set forth for the month
of May 2017. See Rev. Rul. 2017-11, page 1230.
Section 7520.—Valuation
Tables
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of May
2017. See Rev. Rul. 2017-11, page 1230.
Section 7872.—Treatment
of Loans With Below-
Market Interest Rates
The applicable federal short-term, mid-term, and
long-term rates are set forth for the month of May
2017. See Rev. Rul. 2017-11, page 1230.
Bulletin No. 2017–19May 8, 2017
1231

Part III. Administrative, Procedural, and Miscellaneous
Update for Weighted
Average Interest Rates,
Yield Curves, and Segment
Rates
Notice 2017–27
This notice provides guidance on the
corporate bond monthly yield curve, the
corresponding spot segment rates used un-
der § 417(e)(3), and the 24-month average
segment rates under § 430(h)(2) of the
Internal Revenue Code. In addition, this
notice provides guidance as to the interest
rate on 30-year Treasury securities under
§ 417(e)(3)(A)(ii)(II) as in effect for plan
years beginning before 2008 and the 30-
year Treasury weighted average rate un-
der § 431(c)(6)(E)(ii)(I).
YIELD CURVE AND SEGMENT
RATES
Generally, except for certain plans un-
der sections 104 and 105 of the Pension
Protection Act of 2006 and CSEC plans
under § 414(y), § 430 of the Code speci-
fies the minimum funding requirements
that apply to single-employer plans pursu-
ant to § 412. Section 430(h)(2) specifies
the interest rates that must be used to
determine a plan’s target normal cost and
funding target. Under this provision, pres-
ent value is generally determined using
three 24-month average interest rates
(“segment rates”), each of which applies
to cash flows during specified periods. To
the extent provided under § 430(h)(2)
(C)(iv), these segment rates are adjusted
by the applicable percentage of the 25-
year average segment rates for the period
ending September 30 of the year preced-
ing the calendar year in which the plan
year begins.
1
However, an election may
be made under § 430(h)(2)(D)(ii) to use
the monthly yield curve in place of the
segment rates.
Notice 2007– 81, 2007– 44 I.R.B. 899,
provides guidelines for determining the
monthly corporate bond yield curve, and
the 24-month average corporate bond seg-
ment rates used to compute the target nor-
mal cost and the funding target. Consis-
tent with the methodology specified in
Notice 2007– 81, the monthly corporate
bond yield curve derived from March
2017 data is in Table I at the end of this
notice. The spot first, second, and third
segment rates for the month of March
2017 are, respectively, 2.06, 3.95, and
4.75.
The 24-month average segment rates
determined under § 430(h)(2)(C)(i)through
(iii) must be adjusted pursuant to
§ 430(h)(2)(C)(iv) to be within the appli-
cable minimum and maximum percent-
ages of the corresponding 25-year average
segment rates. For plan years beginning
before 2021, the applicable minimum
percentage is 90% and the applicable
maximum percentage is 110%. The 25-
yearaverage segment rates for plan years
beginning in 2015, 2016, and 2017 were
published in Notice 2014 –50, 2014 – 40
I.R.B. 590, Notice 2015– 61, 2015–39 I.R.B.
408, and Notice 2016 –54, 2016 – 40 I.R.B.
429, respectively.
24-MONTH AVERAGE CORPORATE
BOND SEGMENT RATES
The three 24-month average corporate
bond segment rates applicable for April
2017 without adjustment for the 25-year
average segment rate limits are as follows:
Applicable
Month
First
Segment
Second
Segment
Third
Segment
April 20171.653.824.76
Based on § 430(h)(2)(C)(iv), the 24-
month averages applicable for April 2017
adjusted to be within the applicable min-
imum and maximum percentages of the
corresponding 25-year average segment
rates, are as follows:
For Plan
Years
Beginning
In
Adjusted 24-Month Average
Segment Rates
Applicable Month
First
Segment
Second
Segment
Third
Segment
2016April20174.435.916.65
2017April20174.165.726.48
1
Pursuant to § 433(h)(3)(A), the 3
rd
segment rate determined under § 430(h)(2)(C) is used to determine the current liability of a CSEC plan (which is used to calculate the minimum amount
of the full funding limitation under § 433(c)(7)(C)).
May 8, 2017Bulletin No. 2017–19
1232

30-YEAR TREASURY SECURITIES
INTEREST RATES
Generally for plan years beginning af-
ter 2007, § 431 specifies the minimum
funding requirements that apply to mul-
tiemployer plans pursuant to § 412. Sec-
tion 431(c)(6)(B) specifies a minimum
amount for the full-funding limitation
described in § 431(c)(6)(A), based on
the plan’s current liability. Section
431(c)(6)(E)(ii)(I) provides that the inter-
est rate used to calculate current liability
for this purpose must be no more than 5
percent above and no more than 10 per-
cent below the weighted average of the
rates of interest on 30-year Treasury se-
curities during the four-year period ending
on the last day before the beginning of the
plan year. Notice 88 –73, 1988 –2 C.B.
383, provides guidelines for determining
the weighted average interest rate. The
rate of interest on 30-year Treasury secu-
rities for March 2017 is 3.08 percent. The
Service determined this rate as the aver-
age of the daily determinations of yield on
the 30-year Treasury bond maturing in
February 2047. For plan years beginning
in the month shown below, the weighted
average of the rates of interest on 30-year
Treasury securities and the permissible
range of rates used to calculate current
liability are as follows:
For Plan Years
Beginning in
30-Year
Treasury
Weighted
Average
Permissible Range
MonthYear90%to105%
April20172.912.623.05
MINIMUM PRESENT VALUE
SEGMENT RATES
In general, the applicable interest rates
under § 417(e)(3)(D) are segment rates
computed without regard to a 24-month
average. Notice 2007– 81 provides guide-
lines for determining the minimum pres-
ent value segment rates. Pursuant to that
notice, the minimum present value seg-
ment rates determined for March 2017 are
as follows:
First
Segment
Second
Segment
Third
Segment
2.063.954.75
DRAFTING INFORMATION
The principal author of this notice is
Tom Morgan of the Office of the Associate
Chief Counsel (Tax Exempt and Gov-
ernment Entities). However, other per-
sonnel from the IRS participated in the
development of this guidance. For further
information regarding this notice, contact
Mr. Morgan at 202-317-6700 or Tony
Montanaro at 202-317-8698 (not toll-free
numbers).
Bulletin No. 2017–19May 8, 2017
1233

Table I
Monthly Yield Curve for March 2017
Derived from March 2017 Data
MaturityYieldMaturityYieldMaturityYieldMaturityYieldMaturityYield
0.51.2520.54.5140.54.7860.54.8880.54.92
1.01.4721.04.5341.04.7961.04.8881.04.93
1.51.6921.54.5441.54.7961.54.8881.54.93
2.01.8822.04.5542.04.7962.04.8882.04.93
2.52.0422.54.5642.54.8062.54.8882.54.93
3.02.1823.04.5743.04.8063.04.8883.04.93
3.52.3223.54.5843.54.8063.54.8983.54.93
4.02.4524.04.5944.04.8164.04.8984.04.93
4.52.5724.54.6044.54.8164.54.8984.54.93
5.02.7025.04.6145.04.8165.04.8985.04.93
5.52.8225.54.6245.54.8165.54.8985.54.93
6.02.9426.04.6246.04.8266.04.8986.04.93
6.53.0626.54.6346.54.8266.54.8986.54.93
7.03.1827.04.6447.04.8267.04.9087.04.94
7.53.2927.54.6547.54.8267.54.9087.54.94
8.03.4028.04.6548.04.8368.04.9088.04.94
8.53.5028.54.6648.54.8368.54.9088.54.94
9.03.5929.04.6749.04.8369.04.9089.04.94
9.53.6829.54.6849.54.8369.54.9089.54.94
10.03.7730.04.6850.04.8470.04.9090.04.94
10.53.8430.54.6950.54.8470.54.9090.54.94
11.03.9231.04.6951.04.8471.04.9191.04.94
11.53.9831.54.7051.54.8471.54.9191.54.94
12.04.0432.04.7152.04.8572.04.9192.04.94
12.54.0932.54.7152.54.8572.54.9192.54.94
13.04.1433.04.7253.04.8573.04.9193.04.94
13.54.1933.54.7253.54.8573.54.9193.54.94
14.04.2334.04.7354.04.8574.04.9194.04.95
14.54.2634.54.7354.54.8674.54.9194.54.95
15.04.3035.04.7455.04.8675.04.9195.04.95
15.54.3335.54.7455.54.8675.54.9295.54.95
16.04.3536.04.7556.04.8676.04.9296.04.95
16.54.3836.54.7556.54.8676.54.9296.54.95
17.04.4037.04.7657.04.8777.04.9297.04.95
17.54.4237.54.7657.54.8777.54.9297.54.95
18.04.4438.04.7658.04.8778.04.9298.04.95
18.54.4638.54.7758.54.8778.54.9298.54.95
19.04.4739.04.7759.04.8779.04.9299.04.95
19.54.4939.54.7859.54.8779.54.9299.54.95
20.04.5040.04.7860.04.8880.04.92100.04.95
May 8, 2017Bulletin No. 2017–19
1234

Public Comment Invited on
Recommendations for
2017–2018 Priority
Guidance Plan
Notice 2017–28
The Department of the Treasury (Trea-
sury Department) and the Internal Reve-
nue Service (Service) invite public com-
ment on recommendations for items that
should be included on the 2017–2018 Pri-
ority Guidance Plan.
The Treasury Department’s Office of
Tax Policy and the Service use the Prior-
ity Guidance Plan each year to identify
and prioritize the tax issues that should be
addressed through regulations, revenue
rulings, revenue procedures, notices, and
other published administrative guidance.
The 2017–2018 Priority Guidance Plan
will identify guidance projects that the
Treasury Department and the Service in-
tend to work on as priorities during the
period from July 1, 2017, through June 30,
2018.
The Treasury Department and the Ser-
vice recognize the importance of public
input in formulating a Priority Guidance
Plan that focuses resources on guidance
items that are most important to taxpayers
and tax administration. Published guid-
ance plays an important role in increasing
voluntary compliance by helping to clar-
ify ambiguous areas of the tax law. The
published guidance process is most suc-
cessful if the Treasury Department and the
Service have the benefit of the experience
and knowledge of taxpayers and practitio-
ners who must apply the rules implement-
ing the internal revenue laws. This input is
of particular importance in light of Exec-
utive Order 13771 (82 FR 9339) and other
recent executive orders that may affect the
number or type of guidance projects that
can be issued during the 2017–2018 plan
year.
As is the case whenever significant
tax legislation is enacted, the Treasury
Department and the Service will dedi-
cate substantial resources during the
current plan year to published guidance
projects necessary to implement various
provisions of tax legislation enacted
over the past several years or that may
be enacted during the plan year. The
Treasury Department and the Service
will continue to evaluate the priority of
each guidance project taking into ac-
count this tax legislation, as well as
other developments occurring during the
2017–2018 plan year.
In reviewing recommendations and se-
lecting projects for inclusion on the 2017–
2018 Priority Guidance Plan, the Treasury
Department and the Service will consider
the following:
1. Whether the recommended guidance
resolves significant issues relevant to
many taxpayers;
2. Whether the recommended guidance
reduces controversy and lessens the
burden on taxpayers or the Service;
3. Whether the recommendation involves
existing regulations or otherguidance
that is outdated, unnecessary, ineffec-
tive, insufficient, or unnecessarily
burdensome and that should be mod-
ified, streamlined, expanded, re-
placed, or withdrawn;
4. Whether the recommended guidance
would be in accordance with Execu-
tive Order 13771, Executive Order
13777 (82 FR 12285), or other exec-
utive orders.
5. Whether the recommended guidance
promotes sound tax administration;
6. Whether the Service can administer
the recommended guidance on a uni-
form basis; and
7. Whether the recommended guidance
can be drafted in a manner that will
enable taxpayers to easily understand
and apply the guidance.
Please submit recommendations by
June 1, 2017, for possible inclusion on the
original 2017–2018 Priority Guidance
Plan. Taxpayers may, however, submit
recommendations for guidance at any
time during the year. The Treasury De-
partment and the Service may update the
2017–2018 Priority Guidance Plan peri-
odically to reflect additional guidance that
the Treasury Department and the Service
intend to publish during the plan year. The
periodic updates allow the Treasury De-
partment and the Service to respond to the
need for additional guidance that may
arise during the plan year.
Taxpayers are not required to submit
recommendations for guidance in any
particular format. Taxpayers should,
however, briefly describe the recom-
mended guidance and explain the need
for the guidance. In addition, taxpayers
may include an analysis of how the issue
should be resolved. For recommenda-
tions to modify, streamline, or withdraw
existing regulations or other guidance, tax-
payers should explain how thechanges
would reduce taxpayer cost and/or burden
or benefit tax administration. It would be
helpful if taxpayers suggesting more than
one guidance project prioritize the proj-
ects by order of importance. If a large
number of projects are being suggested, it
would be helpful if the projects were
grouped in terms of high, medium, or low
priority. Requests for guidance in the form
of petitions for rulemaking will be consid-
ered with other recommendations for
guidance in accordance with the consider-
ations described in this notice.
Taxpayers may mail comments to:
Internal Revenue Service
Attn: CC:PA:LPD:PR (Notice 2017–
28) Room 5203
P.O. Box 7604
Ben Franklin Station
Washington, D.C. 20044
or hand deliver comments Monday
through Friday between the hours of 8
a.m. and 4 p.m. to:
Courier’s Desk
Internal Revenue Service
Attn: CC:PA:LPD:PR (Notice 2017–28)
1111 Constitution Avenue, N.W.
Washington, D.C. 20224
Alternatively, taxpayers may submit
comments electronically via the Federal
eRulemaking Portal at www.regulations.
gov (type IRS–2017– 0008 in the search
field on the regulations.gov homepage to
find this notice and submit comments). All
recommendations for guidance submitted
by the public in response to this notice
will be available for public inspection and
copying in their entirety. For further in-
formation regarding this notice, contact
Emily M. Lesniak of the Office of Asso-
ciate Chief Counsel (Procedure and Ad-
ministration) at (202) 317-3400 (not a
toll-free number).
Bulletin No. 2017–19May 8, 2017
1235

26 CFR 1.168(k)–1: Additional first year deprecia-
tion.(Also Part 1, § 179.)
Rev. Proc. 2017–33
SECTION 1. PURPOSE
This revenue procedure provides guid-
ance under §§ 124(c)(2), 124(d), 124(e),
143(b), and 167(b) of the Protecting
Americans From Tax Hikes Act of 2015
(PATH Act), enacted as Division Q of the
Consolidated Appropriations Act, 2016,
Pub. L. No. 114 –113, 129 Stat. 2242
(Dec. 18, 2015). Sections 124(c)(2), (d),
and (e) of the PATH Act amend § 179 of
the Internal Revenue Code by (i) making
permanent the treatment of qualified real
property as § 179 property under § 179(f),
(ii) making permanent the permission
granted under § 179(c)(2) to revoke with-
out the consent of the Commissioner of
Internal Revenue (Commissioner) any
election made under § 179 and any spec-
ification contained in that election, and
(iii) allowing certain air conditioning or
heating units to be eligible as § 179 prop-
erty under § 179(d)(1). Section 143(b) of
the PATH Act amends § 168(k) by (i)
extending the placed-in-service date for
property to qualify for the additional first
year depreciation deduction, (ii) modify-
ing the definition of qualified property un-
der § 168(k)(2), (iii) extending and mod-
ifying the election under § 168(k)(4) to
increase the alternative minimum tax
(AMT) credit limitation in lieu of the ad-
ditional first year depreciation deduction,
(iv) adding § 168(k)(5), which allows a
taxpayer to elect to deduct the additional
first year depreciation for certain plants
bearing fruits and nuts before such
plants are placed in service, (v) adding
§ 168(k)(6), which provides a phase down
of the additional first year depreciation
deduction percentage for future taxable
years, and (vi) adding § 168(k)(7), which
allows a taxpayer to elect not to deduct
additional first year depreciation for any
class of property. Section 167(b) of the
PATH Act amends § 168(j) by adding
new § 168(j)(8), which allows a taxpayer
to elect not to apply § 168(j) for any class
of property. This revenue procedure does
not reflect any proposed technical correc-
tions to the PATH Act. This revenue pro-
cedure also does not provide guidance re-
lating to the extension and modification of
the election under § 168(k)(4) to increase
the AMT credit limitation in lieu of the
additional first year depreciation deduc-
tion. The Department of the Treasury
(Treasury Department) and the Internal
Revenue Service (IRS) anticipate issu-
ing guidance regarding the extension
and modification of the election under
§ 168(k)(4) in a separate revenue proce-
dure.
SECTION 2. BACKGROUND
.01Modifications to § 179.
(1) Section 179(a) allows a taxpayer to
elect to treat the cost (or a portion of the
cost) of any § 179 property as an expense
for the taxable year in which the taxpayer
places the property in service. Section
179(b)(1) and (2) prescribe a dollar limi-
tation on the aggregate cost of § 179 prop-
erty that can be treated as an expense
under § 179(a). The dollar limitation is the
amount under § 179(b)(1) (the § 179(b)(1)
limitation), reduced (but not below zero)
by the amount by which the cost of § 179
property placed in service during the tax-
able year exceeds the amount under
§ 179(b)(2) (the § 179(b)(2) limitation).
For taxable years beginning after 2014,
the § 179(b)(1) limitation is $500,000 and
the § 179(b)(2) limitation is $2,000,000.
Pursuant to § 179(b)(6), these limitation
amounts are adjusted for inflation for tax-
able years beginning after 2015. For tax-
able years beginning in 2016, section 3.03
of Rev. Proc. 2016 –14, 2016 –9 I.R.B.
365, provides that the § 179(b)(1) limita-
tion and the § 179(b)(2) limitation, ad-
justed for inflation, are $500,000 and
$2,010,000, respectively. For taxable
years beginning in 2017, section 3.25 of
Rev. Proc. 2016 –55, 2016 – 45 I.R.B.
707, provides that the § 179(b)(1) limi-
tation and the § 179(b)(2) limitation,
adjusted for inflation, are $510,000 and
$2,030,000, respectively.
(2) Section 179(b)(3)(A) provides that
a taxpayer’s § 179 deduction for any
taxable year, after application of the
§ 179(b)(1) and (2) limitations, is limited
to the taxpayer’s taxable income for that
taxable year that is derived from the tax-
payer’s active conduct of any trade or
business during that taxable year (taxable
income limitation). Section 179(b)(3)(B)
provides that the amount of any cost of
§ 179 property elected to be expensed in a
taxable year that is disallowed asa§179
deduction under the taxable income limi-
tation may be carried forward for an un-
limited number of years and may be de-
ducted under § 179(a) in a future year,
subject to the same limitations.
(3) If a taxpayer elects to apply
§ 179(f), § 179(f)(1) provides that § 179
property includes qualified real property,
as defined in § 179(f)(2). Prior to amend-
ment by the PATH Act, § 179(f) applied
to qualified real property placed in service
in any taxable year beginning in 2010,
2011, 2012, 2013, or 2014. Section
124(c)(1) of the PATH Act extended the
application of § 179(f) to qualified real
property placed in service in any taxable
year beginning after 2009 and before
2016. As a result of the amendment by
§ 124(c)(1) of the PATH Act, § 179(f)(3)
provided that the maximum amount of
qualified real property that may be ex-
pensed under § 179(a) for any taxable
year beginning after 2009 and before
2016 was $250,000. Further, § 179(f)(4)
provided that, notwithstanding § 179(b)
(3)(B), a taxpayer that elected to apply
§ 179(f) and elected to expense under
§ 179(a) the cost (or a portion of the cost)
of qualified real property placed in service
during any taxable year beginning after
2009 and before 2016 could not carry over
to any taxable year beginning after 2015
the amount of any cost of such property
that was disallowed as a § 179 deduction
under the taxable income limitation of
§ 179(b)(3)(A). To the extent that any
§ 179 deduction attributable to qualified
real property was not allowed to be car-
ried over to a taxable year beginning after
2015, that amount was required to be
treated as an amount for which an election
under § 179 was not made and as property
placed in service on thefirst day of the
taxpayer’s last taxable year beginning in
2015 for purposes of computing depre-
ciation. Rev. Proc. 2016 – 48, 2016 –37
I.R.B. 348, provides guidance under
§ 124(c)(1) of the PATH Act.
Section 124(c)(2) of the PATH Act
further amends § 179(f) by making per-
manent the treatment of qualified real
property as § 179 property if the taxpayer
elects to apply § 179(f). Section 124(c)(2)
of the PATH Act also amends § 179(f) by
striking paragraphs (3) and (4). Section
124(g)(2) of the PATH Act provides that
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the amendments made by § 124(c)(2) of
the PATH Act apply to taxable years be-
ginning after December 31, 2015. Section
3.01 of this revenue procedure addresses
the application of these revised rules.
(4) Section 179(c) provides the rules
for making and revoking elections under
§ 179 (§ 179 election). Pursuant to
§ 179(c)(1), a § 179 election is made in
the manner prescribed by regulations.
Prior to amendment by § 124(d) of the
PATH Act, § 179(c)(2) provided that a
§ 179 election for taxable years beginning
after 2002 and before 2015 may be re-
voked by the taxpayer with respect to any
§ 179 property. Section 1.179 –5(c)(1) of
the Income Tax Regulations provides that
for any taxable year beginning after 2002
and before 2008, a taxpayer is permitted
to make or revoke a § 179 election with-
out the consent of the Commissioner on
an amended Federal tax return for that
taxable year. Section 1.179 –5(c) was pro-
mulgated in 2005 and has not been
amended to reflect the extensions of
§ 179(c)(2) to taxable years beginning be-
fore 2015. However, in 2008, the Treasury
Department and the IRS issued Rev. Proc.
2008 –54, 2008 –2 C.B. 722. Section 7 of
Rev. Proc. 2008 –54 provides that for a
taxable year beginning after 2007 and be-
fore the last year provided in § 179(c)(2)
for revoking a § 179 election by a tax-
payer for any § 179 property, the taxpayer
will be permitted to make a § 179 election
on an amended return for that taxable year
without the Commissioner’s consent. Sec-
tion 7 of Rev. Proc. 2008 –54 further pro-
vides that until § 1.179 –5(c) is amended
to incorporate this guidance, taxpayers
may rely on such guidance.
Section 124(d) of the PATH Act
amends § 179(c)(2) to make permanent
the permission granted to a taxpayer to
revoke a § 179 election for any § 179
property without the Commissioner’s con-
sent. This amendment applies to taxable
years beginning after 2014. As a result,
some taxpayers are uncertain about
whether a § 179 election for taxable years
beginning after 2014 may be made on an
amended Federal tax return without the
Commissioner’s consent. Section 3.02 of
this revenue procedure provides the rules
for making such a § 179 election.
(5) Section 179(d)(1) defines the term
“§ 179 property.” Prior to amendment by
the PATH Act, § 179(d)(1) defined § 179
property as property that is: (A)(i) tangi-
ble property to which § 168 applies, or
(ii) computer software, as defined in
§ 197(e)(3)(B), that is described in
§ 197(e)(3)(A)(i), to which § 167 applies,
and that is placed in service in a taxable
year beginning after 2002 and before
2015; (B) § 1245 property, as defined in
§ 1245(a)(3); and (C) acquired by pur-
chase for use in the active conduct of a
trade or business. Prior to amendment by
the PATH Act, § 179(d)(1) further pro-
vided that § 179 property does not include
any property described in § 50(b) and
does not include air conditioning or heat-
ing units.
Section 124(b) of the PATH Act
amends § 179(d)(1)(A)(ii) to make perma-
nent the treatment of computer software,
as defined in § 197(e)(3)(B), that is de-
scribed in § 197(e)(3)(A)(i), to which
§ 167 applies, as § 179 property. This
amendment applies to taxable years be-
ginning after 2014. Section 124(e) of the
PATH Act also amends § 179(d)(1) to
allow air conditioning or heating units to
be § 179 property. This amendment ap-
plies to taxable years beginning after
2015.
Some taxpayers have inquired about
what types of air conditioning or heating
units qualify as § 179 property. Section
3.03 of this revenue procedure addresses
this issue.
.02Modifications to § 168(k).
(1) Prior to amendment by the PATH
Act, § 168(k)(1) allowed a 50-percent ad-
ditional first year depreciation deduction
for qualified property that, as provided by
§ 168(k)(2)(A), was acquired by a tax-
payer after 2007 and placed in service by
the taxpayer before 2015 (before 2016
in the case of property described in
§ 168(k)(2)(B) or (C)). Section 143(a)(1)
of the PATH Act amends § 168(k)(2)(A)
by extending the placed-in-service date to
before 2016 (before 2017 in the case of
property described in § 168(k)(2)(B) or
(C)), and extending other dates in
§ 168(k)(2) by changing “January 1,
2015” each place it appears to “January 1,
2016.” Rev. Proc. 2016 – 48 provides
guidance under § 143(a)(1) of the PATH
Act.
(2) Section 143(b)(1) of the PATH Act
further amends § 168(k)(2) by extending
the placed-in-service date to before 2020
(before 2021 in the case of property de-
scribed in § 168(k)(2)(B) or (C)), and by
modifying the definition of qualified prop-
erty. As amended by § 143(b)(1) of the
PATH Act, qualified property under
§ 168(k)(2)(A) includes property that is
qualified improvement property instead of
qualified leasehold improvement prop-
erty. The term “qualified improvement
property” is defined in § 168(k)(3), as
amended by § 143(b)(2) of the PATH Act.
Further, qualified property no longer has
to meet the acquisition date requirements
in § 168(k)(2)(A)(iii) as in effect before
the enactment of the PATH Act. Section
143(b)(1) of the PATH Act also modifies
the property described in § 168(k)(2)(B)
and (C), including by imposing a new
acquisition date requirement, and modi-
fies the special rules under § 168(k)(2)(E)
by deleting the related party rules in
§ 168(k)(2)(E)(iv) that were in effect be-
fore the enactment of the PATH Act.
Section 143(b)(5) of the PATH Act
amends § 168(k) by adding § 168(k)(6) to
the Code. It provides that the additional
first year depreciation deduction percentage
of 50 percent is phased down beginning for
qualified property placed in service after
December 31, 2017 (after December 31,
2018, for property described in § 168(k)(2)(B)
or (C)). Thepercentage is 40 percent for
qualified property placed in service in
2018 (in 2019 for property described
in § 168(k)(2)(B) or (C), determined
by substituting “2019” for “2020” in
§ 168(k)(2)(B)(i)(III) and (ii), and
§ 168(k)(2)(E)(i)), and is 30 percent for
qualified property placed in service in
2019 (in 2020 for property described in
§ 168(k)(2)(B) or (C)).
Section 143(b)(6)(D) of the PATH Act
further amends § 168(k) by adding
§ 168(k)(7) to the Code. It allows a tax-
payer to elect not to deduct additional first
year depreciation for any class of property
placed in service by the taxpayer in the
same taxable year. This election is similar
to the election provided under § 168(k)
(2)(D)(iii) as in effect before the enact-
ment of the PATH Act.
Pursuant to § 143(b)(7)(A) of the
PATH Act, these amendments apply to
property placed in service after December
31, 2015. Sections 4.01 through 4.04 of
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1237

this revenue procedure address the appli-
cation of these revised rules.
(3) Section 143(b)(4) of the PATH
Act also amends § 168(k) by adding
§ 168(k)(5) to the Code. It allows a tax-
payer to elect to deduct additional first
year depreciation for any specified plant
that is planted before January 1, 2020, or
grafted before that date to a plant that has
already been planted, by the taxpayer in
the ordinary course of its farming busi-
ness, as defined in § 263A(e)(4). If the
taxpayer makes this election, the addi-
tional first year depreciation deduction is
allowable for any specified plant for the
taxable year in which that specified plant
is planted or grafted and that specified
plant is not treated as qualified property
under § 168(k) in the plant’s placed-in-
service year. The percentage of the addi-
tional first year depreciation deduction is
(i) 50 percent for any specified plant
planted or grafted after 2015 and before
2018, (ii) 40 percent for any specified
plant planted or grafted during 2018, and
(iii) 30 percent for any specified plant
planted or grafted during 2019.
Aspecifiedplantisdefinedin
§ 168(k)(5)(B) as (i) anytree or vine that
bears fruits or nuts, and (ii) any other plant
that will have more than one yield of fruits
or nuts and that generally has a pre-
productive period of more than two years
from the time of planting or grafting to the
time at which such plant begins bearing
fruits or nuts. The term “specified plant”
does not include any property that is planted
or grafted outside of the United States.
Section 143(b)(7)(C) of the PATH Act
provides that § 168(k)(5) applies to spec-
ified plants, as defined in § 168(k)(5)(B),
planted or grafted after December 31,
2015.
Section 4.05 of this revenue procedure
provides procedures for making the elec-
tion to apply § 168(k)(5) (§ 168(k)(5)
election). TheTreasury Department and
IRS understand that some taxpayers are un-
certain as to whether, if such election is
made for a specified plant, a § 179 election
for the specified plant in its placed-in-
service year is based on the adjusted basis of
the specified plant, or on the original cost of
the specified plant by recapturing the addi-
tional first year depreciation deduction. To
address this uncertainty, section 4.05 of this
revenue procedure also clarifies how the
§ 168(k)(5) election interacts with the § 179
election.
.03Modification to § 168(j).
(1) Section 168(j) provides that for
purposes of § 168(a), the applicable re-
covery period for qualified Indian reser-
vation property is determined in accor-
dance with the table contained in
§ 168(j)(2) instead of the table contained
in § 168(c). The term “qualified Indian
reservationproperty”isdefinedin
§ 168(j)(4). Section 168(j) does not apply
to property placed in service after Decem-
ber 31, 2016.
(2) Section 167(b) of the PATH Act
amends § 168(j) by redesignating para-
graph (8), as amended by § 167(a) of the
PATH Act, as paragraph (9), and by add-
ing new paragraph (8). New § 168(j)(8)
allows a taxpayer to elect not to apply
§ 168(j) for all property that is in the same
class of property and placed in service in
the same taxable year (the § 168(j)(8)
election). Once made, this election is irre-
vocable. Section 167(c)(2) of the PATH
Act provides that the amendments made
by § 167(b) of the PATH Act apply to
taxable years beginning after December
31, 2015. Section 5 of this revenue proce-
dure provides the procedures for making
the § 168(j)(8) election.
.04Subsequent References. Unless oth-
erwise specifically stated, all references in
the subsequent sections of this revenue pro-
cedure to § 168(k), § 168(j), and § 179 are to
§ 168(k), § 168(j), and § 179 as in effect
after the enactment of the PATH Act.
SECTION 3. SECTION 179
EXPENSING
.01Qualified Real Property. For any
taxable year beginning after December 31,
2015, the § 179(b)(1) and (2) limitation
amounts, and the carryover rules in
§ 179(b)(3)(B) and § 1.179 –3(a), apply to
qualified real property placed in service
by the taxpayer during that taxable year, if
the taxpayer elects to apply § 179(f).
.02Making § 179 Elections by Amended
Returns. For any taxable yearbeginning
after 2014, a taxpayer may makea§179
election with respect to any § 179 prop-
erty without the Commissioner’s consent
on an amended Federal tax return for the
taxable year in which the taxpayer places
in service the § 179 property. The Trea-
sury Department and the IRS intend to
amend § 1.179 –5(c) to incorporate the
guidance set forth under this section 3.02.
Until § 1.179 –5(c) is amended, taxpayers
may rely on the guidance set forth in this
section 3.02.
.03Air Conditioning or Heating Units
Qualifying as § 179 Property.
(1)In general. Except as provided in
section 3.03(2) of this revenue procedure,
an air conditioning or heating unit quali-
fies as § 179 property if such unit is
§ 1245 property, depreciated under § 168,
acquired by purchase for use in the active
conduct of the taxpayer’s trade or busi-
ness, and placed in service by the taxpayer
in a taxable year beginning after 2015. For
example, portable air conditioners, such
as window air conditioning units, and por-
table heaters, such as portable plug-in unit
heaters, that are placed in service by the
taxpayer in a taxable year beginning after
2015 may qualify as § 179 property under
§ 179(d)(1) and § 1.179 – 4(a). Except as
provided in section 3.03(2) of this revenue
procedure, an example of an air condition-
ing or heating unit that will not qualify as
§ 179 property is any component of a
central air conditioning or heating system
of a building, including motors, compres-
sors, pipes, and ducts, whether the com-
ponent is in, on, or adjacent to a building.
See§ 1.48 –1(e)(2).
(2)Qualified real property. If a com-
ponent of a central air conditioning or
heating system of a building meets the
definition of qualified real property, as
defined in § 179(f)(2), and the component
is placed in service by the taxpayer in a
taxable year beginning after 2015, the
component may qualify as § 179 property
if the taxpayer elects to apply § 179(f).
SECTION 4. ADDITIONAL FIRST
YEAR DEPRECIATION (§ 168(k))
.01Qualified Property.
(1)In general. The rules for determin-
ing whether depreciable property is eligi-
ble for the additional first year deprecia-
tion deduction under § 168(k) are similar
to the rules in § 168(k) as in effect before
the enactment of the PATH Act. How-
ever, qualified property under § 168(k)
(2)(A)includes property that is qualified
improvement property instead of quali-
fied leasehold improvement property.Fur-
ther, the acquisition date requirement in
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§ 168(k)(2)(A)(iii) and the related party
rules in § 168(k)(2)(E)(iv), both as in ef-
fect before the enactment of the PATH
Act, do not apply. However, a new acqui-
sition date requirement applies for prop-
erty described in § 168(k)(2)(B) or (C).
(2)Property described in § 168(k)
(2)(B) or (C).
(a)Acquisition date requirement. Qual-
ified property includes any property de-
scribed in § 168(k)(2)(B) or (C). Pursuant
to § 168(k)(2)(B)(i)(III) and (C)(i), prop-
erty is described in § 168(k)(2)(B) or (C)
if the property is acquired by the taxpayer
before January 1, 2020, or is acquired
pursuant to a written contract entered into
before January 1, 2020, assuming all other
requirements in § 168(k)(2)(B) or (C), as
applicable, are met. To determine if the
acquisition date requirement is met, rules
similar to the rules in § 1.168(k)–1(b)(4)
for “qualified property” or for “30-percent
additional first year depreciation deduction”
apply. However, in applying § 1.168(k)–
1(b)(4), § 1.168(k)–1(b)(4)(ii)(A)–(D) and
(iv) do not apply.
(b)Certain aircraft. For aircraft de-
scribed in § 168(k)(2)(C), the nonrefund-
able deposit requirement in § 168(k)
(2)(C)(iii) is satisfied if the purchaser, at
the time of the purchase contract, has
made a nonrefundable deposit of at least
the lesser of 10 percent of the cost of the
aircraft or $100,000.Seesection 5.02 of
Rev. Proc. 2008 –54.
(3)Application of § 1.168(k)–1. For
purposes of the additional first year depre-
ciation deduction, rules similar to the rules
in § 1.168(k)–1 for “qualified property” or
for “30-percent additional first year depre-
ciation deduction” apply to § 168(k)(2)
and (3). However, in applying § 1.168(k)–
1(d)(1)(i), the computation of the allowable
50-percent additional first year depreciation
deduction is made in accordance with the
rules for 50-percent bonus depreciation
property and, in applying § 1.168(k)–
1(f)(5)(iii)(A), the rules for 50-percent addi-
tional first year depreciation deduction ap-
ply. In applying § 1.168(k)–1(c) to qualified
improvement property, see section 4.02(3)
of this revenue procedure.
.02Qualified Improvement Property.
(1)In general. Section 168(k)(3) de-
fines the term “qualified improvement
property” as any improvement to an inte-
rior portion of a building that is nonresi-
dential real property if the improvement is
placed in service after the date the build-
ing was first placed in service. However,
qualified improvement property does not
include any improvement attributable to
the enlargement of the building, any ele-
vator or escalator, or the internal structural
framework of the building.
(2)Building was first placed in service.
For purposes of § 168(k)(3), the term
“first placed in service” means the first
time the building is placed in service by
any person.See§ 1.168(k)–1(c)(1)(iii). A
building is first placed in service when
first placed in a condition or state of read-
iness and availability for a specifically
assigned function, whether in a trade or
business, in the production of income, in a
tax-exempt activity, or in a personal ac-
tivity.See§ 1.46 –3(d)(1)(ii) and (d)(2).
(3)Application of § 1.168(k)–1(c).
Rules similar to the rules in § 1.168(k)–
1(c) apply to depreciable property that
isqualifiedimprovementproperty.
However, in applying § 1.168(k)–1(c),
§1.168(k)–1(c)(2)(iii),(3)(ii),and
(3)(vi) do not apply.
(4)Qualified restaurant property.
Qualified property that is placed in service
by the taxpayer after December 31, 2015,
and that meets the definition of both
qualified improvement property and qual-
ified restaurant property, as defined in
§ 168(e)(7), is eligible for the additional
first year depreciation deduction under
§ 168(k), assuming all other requirements
in § 168(k) are met.
(5)Examples. The following examples
illustrate the provisions concerning quali-
fied improvement property. Assume that
all of the improvements in the examples
are required to be capitalized under
§ 263(a) and/or § 263A.
(a)Example 1 – Qualified improvement property.
In 2010,Aplaces in service a new office building. In
February 2016,Asells this office building toBat fair
market value.Buses the office building in its trade or
business. In March 2016,Bbegins to construct im-
provements to the interior portion of the office building
and places the improvements in service in December
2016. Because the office building was first placed in
service in 2010 and the improvements made byBto the
interior portion of the office building are placed in
service after that date, the improvements that are
§ 1250 property are qualified improvement property,
assuming all other requirements in § 168(k)(3) and
§ 1.168(k)–1(c), taking into account section 4.02(3) of
this revenue procedure, are met.
(b)Example 2 – Qualified improvement property.
In 2015,C, a corporation and manufacturer, enters
into a written contract withXforXto construct a
new building for use byCin its trade or business.
The building will house a manufacturing operation
and office space. The initial construction plans did
not include a private restroom for the owner ofC.
During the construction of the building,Centers into
a written contract withYto construct a private rest-
room in the new building for the owner ofC.On
May 27, 2016,Cplaces in service the building,
except for the private restroom. On May 28, 2016,
the private restroom in the building for the owner of
Cis placed in service. Because the building is first
placed in service on May 27, 2016, and the private
restroom is placed in service on May 28, 2016, the
assets in the private restroom that are § 1250 prop-
erty are qualified improvement property, assuming
all other requirements in § 168(k)(3) and § 1.168(k)–
1(c), taking into account section 4.02(3) of this rev-
enue procedure, are met.
(c)Example 3 – Qualified improvement property.
The facts are the same as inExample 2, exceptC
enters into an amendment to the existing written
contract withX, the contractor of the building, forX
to construct a private restroom in the building for the
owner ofC. Because the building is first placed in
service on May 27, 2016, and the private restroom is
placed in service on May 28, 2016, the result is the
same as inExample 2.
(d)Example 4 – Qualified improvement property.
Dis engaged in the commercial building rental busi-
ness. In March 2015,Denters into a written contract
withZto construct a multi-story building. Pursuant
to this contract,Zconstructs a completely finished
exterior of the building and a minimally finished
interior of the building with only elevators, heating,
ventilation, and air conditioning systems, plumbing,
restrooms, and concrete floors. In December 2015,D
andEentered into a lease agreement providing that
Ewill lease one floor of the new building andEwill
install on that floor drop ceilings, lighting, interior
walls, electrical outlets, carpeting, and trade fixtures
necessary for the operation ofE’s trade or business
(collectively referred to as a build-out). On February
8, 2016,Dplaces in service the new building. On
June 4, 2016,Eplaces in service the build-out.
Because the building is first placed in service on
February 8, 2016, and the build-out is placed in
service after that date, the assets of the build-out that
are § 1250 property are qualified improvement prop-
erty, assuming all other requirements in § 168(k)(3)
and § 1.168(k)–1(c), taking into account section
4.02(3) of this revenue procedure, are met.
(e)Example 5 – Qualified restaurant property
that is qualified improvement property. In 2016,F
constructs and places in service an improvement to a
restaurant building and that improvement meets the
definitions of both qualified restaurant property un-
der § 168(e)(7) and qualified improvement property
under § 168(k)(3). Accordingly, the improvement is
eligible for the additional first year depreciation de-
duction provided by § 168(k), assuming all other
requirements in § 168(k) are met.
(f)Example 6 – Qualified restaurant property
that is not qualified improvement property. In 2016,
Gconstructs and places in service a new restaurant
building and that building meets the definition of
Bulletin No. 2017–19May 8, 2017
1239

qualified restaurant property under § 168(e)(7).
However, that building is not qualified improvement
property under § 168(k)(3). Accordingly, the build-
ing is not eligible for the additional first year depre-
ciation deduction provided by § 168(k).
.03Phase Down of Additional First
Year Depreciation Deduction
Percentage.
(1)In general. Pursuant to § 168(k)(6),
the additional first year depreciation de-
duction percentage of 50 percent is
phased down beginning for qualified
property placed in service after December
31, 2017 (after December 31, 2018, for
property described in § 168(k)(2)(B) or
(C)). The tables below provide the addi-
tional first year depreciation deduction
percentages for qualified property placed
in service by the taxpayer after 2015.
(2)Additional first year depreciation
deduction percentages.
(a) The table below provides the addi-
tional first year depreciation deduction
percentages for qualified property that is
not described in § 168(k)(2)(B) or (C):
Placed-in-Service Year
Additional First Year Depreciation
Deduction Percentage
201650%
201750%
201840%
201930%
After 20190%
(b) The table below provides the additional first year depreciation deduction percentages for qualified property that is described
in § 168(k)(2)(B) or (C):
Placed-in-Service
Year
Acquired, or Acquired Pursuant to a
Written Contract Entered Into:
Additional First Year Depreciation
Deduction Percentage
2016Before 202050%
2017Before 202050%
2018Before 202050%
2019Before 201940%*
2019During 201930%*
2020Before 202030%**
2020After 20190%
After 2020Before 2020 or After 20190%
* For qualified property described in § 168(k)(2)(B) and placed in service in 2019 but acquired, or acquired pursuant to a
written contract entered into, before 2019, the 40% applies only to the property’s unadjusted depreciable basis attributable
to the property’s manufacture, construction, or production before January 1, 2019.See§ 168(k)(2)(B)(ii) and (6)(A) and
§ 1.168(k)–1(d)(1)(ii), taking into account section 4.01(3) of this revenue procedure. For qualified property described in
§ 168(k)(2)(B), placed in service in 2019, and acquired, or acquired pursuant to a written contract entered into, in 2019,
the 30% applies only to the property’s unadjusted depreciable basis attributable to the property’s manufacture, construc-
tion, or production before January 1, 2020. For qualified property described in § 168(k)(2)(C) and placed in service in
2019, the 30% and 40% apply to the property’s unadjusted depreciable basis.
** For qualified property described in § 168(k)(2)(B) and placed in service in 2020 but acquired, or acquired pursuant to a
written contract entered into, before 2020, the 30% applies only to the property’s unadjusted depreciable basis attributable
to the property’s manufacture, construction, or production before January 1, 2020.See§ 168(k)(2)(B)(ii) and (6)(B) and
§ 1.168(k)–1(d)(1)(ii), taking into account section 4.01(3) of this revenue procedure. For qualified property described in
§ 168(k)(2)(C) and placed in service in 2020 but acquired, or acquired pursuant to a written contract entered into, before
2020, the 30% applies to the property’s unadjusted depreciable basis.
.04Election Not to Deduct the
Additional First Year Depreciation.
(1)In general. The rules for making
the election under § 168(k)(7) not to de-
duct the additional first year depreciation
(the § 168(k)(7) election) are similar to
the rules for making such election under
§ 168(k)(2)(D)(iii) as in effect before the
enactment of the PATH Act. As a result,
the § 168(k)(7) election applies to all
qualified property that is in the same class
of property and placed in service in the
same taxable year. If the § 168(k)(7) elec-
tion is made for a class of property that is
May 8, 2017Bulletin No. 2017–19
1240

qualified property placed in service during
the taxable year, no additional first year
depreciation deduction is allowable for
that property and § 168(k)(2)(F) does not
apply to that property. However, that
property is still qualified property for pur-
poses of § 168(k), assuming all the re-
quirements of § 168(k)(2) are met. For
example, if a calendar-year taxpayer
makes the § 168(k)(7) election for a class
of property that is qualified property
placed in service during 2016, the depre-
ciation adjustments under § 56 and the
regulations under § 56 do not apply to the
property to which the election applies for
purposes of computing the taxpayer’s al-
ternative minimum taxable income.See
§ 168(k)(2)(G). However, see section
4.04(3) of this revenue procedure for how
the election not to deduct the additional
first year depreciation applies to a tax-
payer with a taxable year beginning in
2015 and ending in 2016.
(2)Application of § 1.168(k)–1(e). Ex-
cept as provided in section 4.04(3) of this
revenue procedure, rules similar to the
rules in § 1.168(k)–1(e)(2), (3), (5), and
(7) apply for purposes of § 168(k)(7).
(3)Special rules for certain taxpayers.
This section 4.04(3) applies to a taxpayer
with a taxable year beginning in 2015 and
ending in 2016. If such taxpayer makes an
election not to deduct the additional first
year depreciation for a class of property
that is qualified property placed in service
during such taxable year, no additional
first year depreciation deduction is allow-
able for that property and § 168(k)(2)(F),
as in effect before and after the enactment
of the PATH Act, does not apply to that
property. The election is made under
§ 168(k)(2)(D)(iii) as in effect before the
enactment of the PATH Act for property
placed in service in 2015 and under
§ 168(k)(7) for property placed in service
in 2016. For property placed in service in
2015 to which the election applies, the
depreciation adjustments under § 56 and
the regulations under § 56 apply to such
property for purposes of computing the
taxpayer’s alternative minimum taxable
income.See§ 1.168(k)–1(e)(6). For qual-
ified property placed in service in 2016 to
which the election applies, the deprecia-
tion adjustments under § 56 and the reg-
ulations under § 56 do not apply to such
property for purposes of computing the
taxpayer’s alternative minimum taxable
income.See§ 168(k)(2)(G).
.05Special Rules for Certain Plants
Bearing Fruits and Nuts.
(1)Section 168(k)(5) election.
(a)In general. The § 168(k)(5) elec-
tion applies to one or more specified
plants, as defined in § 168(k)(5)(B),
planted or grafted by the taxpayer during
the taxable year for which the § 168(k)(5)
election is made. If a taxpayer makes the
§ 168(k)(5) election for a specified plant,
(i) the additional first year depreciation
deduction provided by § 168(k) is allowed
for that specified plant for regular tax and
alternative minimum tax purposes for the
taxable year in which the specified plant is
planted or grafted by the taxpayer, (ii)that
specified plant is not treated as qualified
property under § 168(k) in its placed-in-
service year, and (iii) the depreciation de-
ductions under § 168 for that specified plant,
after deducting the additional first year de-
preciation, are allowed for its placed-in-
service year and subsequent taxable years.
Further, pursuant to § 263A(c)(7) (as added
to the Code by § 143(b)(6)(H) of the PATH
Act), § 263A does not apply to any amount
deducted under the § 168(k)(5) election.
(b)Time and manner for making the
§ 168(k)(5) election.
(i)In general. Except as provided in
section 4.05(1)(b)(ii) of this revenue pro-
cedure, the § 168(k)(5) election must be
made by the due date, including exten-
sions, of the Federal tax return for the
taxable year in which the taxpayer plants
or grafts the specified plant to which the
election applies. Except as provided in
section 4.05(1)(b)(ii) of this revenue pro-
cedure, the § 168(k)(5) election must be
made in the manner prescribed on Form
4562,Depreciation and Amortization, and
its instructions.
(ii)Deemed election. This section
4.05(1)(b)(ii) applies to a taxpayer that did
not make the § 168(k)(5) election for a
specified plant planted or grafted by the
taxpayer after December 31, 2015, on its
timely filed Federal tax return for its tax-
able year beginning in 2015 and ending in
2016 or its taxable year of less than 12
months beginning and ending in 2016. If
this section 4.05(1)(b)(ii) applies, the tax-
payer will be treated as making the
§ 168(k)(5) election for that specified
plant if the taxpayer:
(A) On that return, deducted the
50-percent additional first year deprecia-
tion for that specified plant; and
(B) Did not revoke the deemed
election provided under this section
4.05(1)(b)(ii) within the time and in the
manner provided in section 4.05(2)(b) of
this revenue procedure.
(2)Revocation of the § 168(k)(5) elec-
tion.
(a)In general. Except as provided in
section 4.05(2)(b) of this revenue proce-
dure, the § 168(k)(5) election, once made,
may be revoked only with the written con-
sent of the Commissioner. To seek the
Commissioner’s consent, the taxpayer
must submit a request for a letter ruling
pursuant to Rev. Proc. 2017–1, 2017–1
I.R.B. 1 (or successor).
(b)Automatic 6-month extension.Ifa
taxpayer made, or would be treated under
section 4.05(1)(ii) of this revenue proce-
dure as having made, the § 168(k)(5) elec-
tion for a specified plant, an automatic
extension of 6 months from the due date,
excluding extensions, of the taxpayer’s
Federal tax return for the taxable year in
which such specified plant is planted or
grafted is granted to revoke that election,
provided the taxpayer timely filed the tax-
payer’s Federal tax return for that taxable
year and, within this 6-month extension
period, the taxpayer, and all taxpayers
whose tax liability would be affected by
the § 168(k)(5) election, files an amended
Federal tax return for that taxable year in
a manner that is consistent with the revo-
cation of the election.
(3)Interaction with § 179. If a taxpayer
makes the § 168(k)(5) election for a spec-
ified plant, the adjusted basis of that spec-
ified plant is reduced by the amount of the
additional first year depreciation deduc-
tion allowed or allowable under § 168(k),
whichever is greater. This remaining ad-
justed basis is the cost of the specified
plant for purposes of § 179, before the
application of § 179(d)(3) and § 1.179 –
4(d).
SECTION 5. ELECTION NOT TO
APPLY § 168(j)
.01In General. The § 168(j)(8) elec-
tion applies to all qualified Indian reser-
vation property, as defined in § 168(j)(4),
Bulletin No. 2017–19May 8, 2017
1241

that is in the same class of property and
placed in service in the same taxable year.
If the § 168(j)(8) election is made for a
class of property that is qualified Indian
reservation property placed in service dur-
ing the taxable year, the applicable recov-
ery period for that property for purposes
of § 168(a) is determined in accordance
with the table contained in § 168(c), and
the depreciation adjustments under § 56
and the regulations under § 56 apply to
that property for purposes of computing
the taxpayer’s alternative minimum tax-
able income. Once made, the § 168(j)(8)
election is irrevocable.
.02Definition of Class of Property. For
purposes of § 168(j)(8) and this section 5,
the term “class of property” means each
class of property described in the table
contained in § 168(j)(2) (for example,
3-year property).
.03Time and Manner for Making the
§ 168(j)(8) Election.
(1)In general. Except as provided in
section 5.03(2) of this revenue procedure,
the § 168(j)(8) election must be made by
the due date, including extensions, of the
Federal tax return for the taxable year in
which the taxpayer places in service the
qualified Indian reservation property. Ex-
cept as provided in section 5.03(2) of this
revenue procedure, the § 168(j)(8) elec-
tion must be made in the manner pre-
scribed on Form 4562,Depreciation and
Amortization, and its instructions.
(2)Deemed election. This section
5.03(2) applies to a taxpayer that did not
make the § 168(j)(8) election within the
time and in the manner provided in sec-
tion 5.03(1) of this revenue procedure for
a class of property that is qualified Indian
reservation property placed in service by
the taxpayer in its taxable year of less than
12 months beginning and ending in 2016.
If this section 5.03(2) applies, the tax-
payer will be treated as making the
§ 168(j)(8) election for a class of property
that is qualified Indian reservation prop-
erty if the taxpayer, on its timely filed
Federal tax return for that taxable year,
determined depreciation for that class of
property under the general depreciation
system of § 168(a) by using the applicable
recovery period for that class of property
in accordance with the table contained in
§ 168(c).
SECTION 6. EFFECT ON OTHER
DOCUMENTS
Section 7 of Rev. Proc. 2008 –54 is
obsoleted for taxable years beginning af-
ter 2014.
SECTION 7. EFFECTIVE DATE
This revenue procedure is effective
April 20, 2017.
SECTION 8. DRAFTING
INFORMATION
The principal author of this revenue
procedure is Elizabeth Binder of the Of-
fice of Associate Chief Counsel (Income
Tax & Accounting). For further informa-
tion regarding this revenue procedure,
contact Ms. Binder at (202) 317-7005 (not
a toll-free number).
May 8, 2017Bulletin No. 2017–19
1242

Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplifieddescribes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus, if
an earlier ruling held that a principle ap-
plied to A, and the new ruling holds that
the same principle also applies to B, the
earlier ruling is amplified. (Compare with
modified, below).
Clarifiedis used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguisheddescribes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modifiedis used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
withamplifiedandclarified, above).
Obsoleteddescribes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transac-
tions. This term is most commonly used in
a ruling that lists previously published rul-
ings that are obsoleted because of changes
in laws or regulations. A ruling may also
be obsoleted because the substance has
been included in regulations subsequently
adopted.
Revokeddescribes situations where the
position in the previously published ruling
is not correct and the correct position is
being stated in a new ruling.
Supersededdescribes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a pe-
riod of time in separate rulings. If the new
ruling does more than restate the sub-
stance of a prior ruling, a combination of
terms is used. For example,modifiedand
supersededdescribes a situation where the
substance of a previously published ruling
is being changed in part and is continued
without change in part and it is desired to
restate the valid portion of the previously
published ruling in a new ruling that is
self contained. In this case, the previously
published ruling is first modified and then,
as modified, is superseded.
Supplementedis used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names
in subsequent rulings. After the original
ruling has been supplemented several
times, a new ruling may be published that
includes the list in the original ruling and
the additions, and supersedes all prior rul-
ings in the series.
Suspendedis used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current
use and formerly used will appear in ma-
terial published in the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE
—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.
Bulletin No. 2017–19May 8, 2017
i

Numerical Finding List
1
Bulletin 2017–1 through 2017–19
Action on Decision:
2017-1, 2017-7 I.R.B.868
2017-2, 2017-15 I.R.B.1072
2017-3, 2017-15 I.R.B.1072
2017-4, 2017-15 I.R.B.1073
Announcements:
2017-01, 2017-08 I.R.B.941
2017-02, 2017-10 I.R.B.1007
2017-03, 2017-15 I.R.B.1077
2017-04, 2017-16 I.R.B.1106
Notices:
2017-1, 2017-2 I.R.B.367
2017-2, 2017-4 I.R.B.539
2017-3, 2017-2 I.R.B.368
2017-4, 2017-4 I.R.B.541
2017-5, 2017-6 I.R.B.779
2017-6, 2017-3 I.R.B.422
2017-7, 2017-3 I.R.B.423
2017-8, 2017-3 I.R.B.423
2017-9, 2017-4 I.R.B.542
2017-10, 2017-4 I.R.B.544
2017-12, 2017-5 I.R.B.742
2017-13, 2017-6 I.R.B.780
2017-14, 2017-6 I.R.B.783
2017-15, 2017-6 I.R.B.783
2017-16, 2017-7 I.R.B.913
2017-17, 2017-15 I.R.B.1074
2017-18, 2017-9 I.R.B.997
2017-19, 2017-9 I.R.B.1000
2017-20, 2017-11 I.R.B.1010
2017-21, 2017-13 I.R.B.1026
2017-22, 2017-13 I.R.B.1033
2017-23, 2017-16 I.R.B.1100
2017-24, 2017-17 I.R.B.1127
2017-25, 2017-17 I.R.B.1127
2017-26, 2017-17 I.R.B.1129
2017-27, 2017-19 I.R.B.1232
2017-28, 2017-19 I.R.B.1235
Proposed Regulations:
REG-137604-07, 2017-7 I.R.B.923
REG-128276-12, 2017-2 I.R.B.369
REG-103477-14, 2017-5 I.R.B.746
REG-112324-15, 2017-4 I.R.B.547
REG-127203-15, 2017-7 I.R.B.918
REG-131643-15, 2017-6 I.R.B.865
REG-134438-15, 2017-2 I.R.B.373
REG-112800-16, 2017-4 I.R.B.569
REG-123829-16, 2017-5 I.R.B.764
REG-123841-16, 2017-5 I.R.B.766
REG-133353-16, 2017-2 I.R.B.372
REG-134247-16, 2017-5 I.R.B.744
REG-135122-16, 2017-9 I.R.B.1005
Revenue Procedures:
2017-1, 2017-1 I.R.B.1
2017-2, 2017-1 I.R.B.106
2017-3, 2017-1 I.R.B.130
2017-4, 2017-1 I.R.B.146
2017-5, 2017-1 I.R.B.230
2017-7, 2017-1 I.R.B.269
2017-12, 2017-3 I.R.B.424
2017-13, 2017-6 I.R.B.787
2017-14, 2017-3 I.R.B.426
2017-15, 2017-3 I.R.B.437
2017-16, 2017-3 I.R.B.501
2017-18, 2017-5 I.R.B.743
2017-19, 2017-7 I.R.B.913
2017-21, 2017-6 I.R.B.791
2017-22, 2017-6 I.R.B.863
2017-23, 2017-7 I.R.B.915
2017-24, 2017-7 I.R.B.916
2017-25, 2017-14 I.R.B.1039
2017-26, 2017-13 I.R.B.1036
2017-27, 2017-14 I.R.B.1042
2017-28, 2017-14 I.R.B.1061
2017-29, 2017-14 I.R.B.1065
2017-30, 2017-18 I.R.B.1131
2017-31, 2017-16 I.R.B.1104
2017-32, 2017-17 I.R.B.1109
2017-33, 2017-19 I.R.B.1236
Revenue Rulings:
2017-1, 2017-3 I.R.B.377
2017-2, 2017-2 I.R.B.364
2017-3, 2017-4 I.R.B.522
2017-4, 2017-6 I.R.B.776
2017-5, 2017-9 I.R.B.1000
2017-6, 2017-12 I.R.B.1011
2017-7, 2017-10 I.R.B.1009
2017-8, 2017-14 I.R.B.1037
2017-10, 2017-17 I.R.B.1108
2017-11, 2017-19 I.R.B.1230
Treasury Decisions:
9794, 2017-2 I.R.B.273
9795, 2017-2 I.R.B.326
9796, 2017-3 I.R.B.380
9801, 2017-2 I.R.B.355
9802, 2017-2 I.R.B.361
9803, 2017-3 I.R.B.384
9804, 2017-3 I.R.B.406
9806, 2017-4 I.R.B.524
9807, 2017-5 I.R.B.573
9808, 2017-5 I.R.B.580
9809, 2017-5 I.R.B.664
9810, 2017-6 I.R.B.775
9811, 2017-7 I.R.B.869
9814, 2017-7 I.R.B.878
9815, 2017-9 I.R.B.944
9817, 2017-9 I.R.B.968
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2016 –27 through 2016 –52 is in Internal Revenue Bulletin
2016 –52, dated December 26, 2016.
May 8, 2017Bulletin No. 2017–19
ii

Finding List of Current Actions on
Previously Published Items
1
Bulletin 2017–1 through 2017–19
Notices:
2002-1
Amplified by
Notice 2017-1, 2017-2 I.R.B.367
2010-46
Obsoleted by
Notice 2017-1, 2017-2 I.R.B.367
2016-29
Modified by
Notice 2017-6, 2017-3 I.R.B.422
Revenue Procedures:
2013-22
Clarified by
Rev. Proc. 2017-18, 2017-05 I.R.B.743
2015-57
Modified by
Rev. Proc. 2017-24, 2017-07 I.R.B.916
Treasury Decisions:
2010-46
Obsoleted by
T.D. 9815 2017-09 I.R.B.944
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2016 –27 through 2016 –52 is in Internal Revenue Bulletin
2016 –52, dated December 26, 2016.
Bulletin No. 2017–19May 8, 2017
iii

INTERNAL REVENUE BULLETIN
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