SECTION 1. PURPOSE

This revenue procedure modifies Rev. Proc. 2009–50, 2009–2 C.B. 617, as modified by Rev. Proc. 2010–24, 2010–25 I.R.B. 764, setting out the cost limitations for expensing property under § 179 of the Internal Revenue Code for taxable years

State and local bonds such as Build America Bonds under §§ 54AA(d), 54AA(g) and 6431, and Recovery Zone Bonds under §§ 1400U–1 through 1400U–3. The analysis in this notice also applies for other deadlines for issuing bonds, such as, among others, the exceptions to the alternative minimum tax preferences and adjustments for interest on certain tax-exempt bonds under §§ 56(g)(4)(B)(iv) and 57(a)(5)(C)(vi), Gulf Opportunity Zone Bonds under § 1400N and various volume cap limitations on State and local bonds (as defined in § 103(c)).

This notice does not apply for purposes of applying the qualified small issuer and de minimis exceptions to the tax-exempt carrying cost disallowance provision under § 265(b)(3) and § 265(b)(7) to drawdown loans. For this purpose, Rev. Rul. 89–70 will continue in effect until further guidance is provided, which guidance will be prospective.