SECTION 3. SECTION 179

EXPENSING

.01 Qualified 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).

.02 Making § 179 Elections by Amended Returns . For any taxable year beginning after 2014, a taxpayer may make a § 179 election with respect to any § 179 property 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 Treasury 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.

.03 Air 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 qualifies 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 business, 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 portable 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 conditioning 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, compressors, pipes, and ducts, whether the component is in, on, or adjacent to a building. See § 1.48–1(e)(2).

(2) Qualified real property . If a component 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).