Rev. Proc. 2026-17, page 805.

This revenue procedure provides guidance on the withdrawal of elections to be excepted trades or businesses under § 163(j)(7) for purposes of the business interest limitation and to make a late election under § 168(k)(7) to be exempt from bonus depreciation. This revenue procedure also provides guidance on the early election or revocation of a CFC group election under 1.163(j)-7(e). Taxpayers in identified fields are permitted to withdraw an election previously made under § 163(j) and make the associated depreciation adjustments under § 168(k) or make a late election out of applying bonus depreciation under § 168(k). Separately, a CFC group may either make or revoke their specific group election regardless of whether the requisite 60-month requirement of § 1.163(j)-7(e)(5)(ii) is satisfied.