SECTION 8. ELECTIVE EXPENSING

PROVISIONS (§ 179D).

01 Deduction for Energy Efficient Commercial Buildings (§ 179D)

(1) Description of change . This change, as described in Rev. Proc. 2012-39, 201241 I. R. B. 470, applies to a taxpayer that wants to change its method of accounting to deduct under § 179D amounts paid or incurred for the installation of energy efficient commercial building property, as defined in § 179D(c)(1). The deduction for energy efficient commercial building property is subject to the limits of § 179D(b) and must be claimed in the taxable year in which the property is placed in service. The basis of the energy efficient commercial building property is reduced by the amount of the § 179D deduction taken and the remaining basis of the energy efficient commercial building property is depreciated over its recovery period.

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(5) Designated automatic accounting method change number . The designated automatic accounting method change number for a change under this section 9 .01 is “18 .” (6) Contact information . For further information regarding a change under this section, contact Bruce Chang at (202) 317-7005 (not a toll-free number) .

SECTION 10 . STARTUP EXPENDITURES AND ORGANIZATIONAL FEES (§§ 195, 248, AND 709)

.01 Start-up expenditures . (1) Description of change and scope . (a) Applicability . This change applies to a taxpayer that wants to change its method of accounting under § 195 to change:

(i) the characterization of an item as a start-up expenditure;

(ii) the determination of the taxable year in which the taxpayer begins the active trade or business to which the start-up expenditures relate; or

(iii) the amortization period of a start-up expenditure to 180 months .

(b) Inapplicability . This change does not apply to:

(i) start-up expenditures paid or incurred before October 23, 2004; or

(ii) start-up expenditures paid or incurred after October 22, 2004, and before August 17, 2011, if the period of limitations on assessment of tax for the taxable year the election under § 1 .1951(b) is deemed made has expired . (2) No rulings . (a) Characterization of item . The consent granted under section 9 of Rev . Proc . 2015-13 for a change specified in section 10 .01(1)(a)(i) of this revenue procedure is not a determination by the Commissioner that the taxpayer has properly characterized an item as a start-up expenditure and does not create any presumption that the proposed characterization of an item as a start-up expenditure is permissible under § 195(c)(1) . The director will ascertain whether the taxpayer’s characterization of an item as a start-up expenditure is permissible .

(b) When active trade or business begins . The consent granted under section 9 of Rev . Proc . 2015-13 for a change specified in section 10.01(1)(a)(ii) of this

(2) Applicability . This change applies to a taxpayer that places in service property for which a deduction is allowed under § 179D(a).

(3) Inapplicability . This change does not apply to a designer to whom the owner of a government building allocates the § 179D deduction.

(4) Manner of making change . A taxpayer making this change must attach to its Form 3115 (the original, the duplicate copy filed with the IRS in Ogden, UT, and any additional copies) a statement with a detailed description of the tax treatment of the property under the taxpayer’s present and proposed methods of accounting.

(5) Certification requirement . In addition to the statement required by section 8. 01(4) of this revenue procedure, a taxpayer making this change must attach to its Form 3115 a certification as required by section 4 of Notice 2006-52, 2006-1 C. B. 1175, or section 5 of Notice 200840, 2008-1 C. B. 725, to demonstrate that the energy efficient commercial building property has achieved the reduction in energy and power costs or in lighting power density necessary to qualify for the § 179D deduction.

(6) No ruling on qualification . The consent granted under section 9 of Rev. Proc. 2015-13, 2015-5 I. R. B. 419, for a change provided in this section 8. 01 is not a determination by the Commissioner that the taxpayer qualifies for a deduction under section 179D. The director will ascertain whether the taxpayer qualifies for a deduction under section 179D (including a review of the required certifications). See section 12 of Rev. Proc. 2015-13.

(7) Designated automatic accounting method change number . The designated automatic accounting method change number for a change under this section 8. 01 is “152. ” (8) Contact information . For further information regarding a change under this section, contact Charles Hyde at (202) 317-5214 (not a toll-free number).