IRS Issues Revenue Procedure on Withdrawal of Business Interest Deduction Limitation, Late Depreciation Elections

The IRS provides transition relief allowing taxpayers to withdraw certain elections made under the business interest deduction limitation rules and make late depreciation elections in response to changes under the One Big Beautiful Bill Act. The guidance permits taxpayers who elected to be treated as an electing real property trade or business, an electing farming business, or an excepted regulated utility trade or business for taxable years beginning in 2022, 2023, or 2024 to withdraw these elections by filing amended returns or administrative adjustment requests by October 15, 2026. Taxpayers withdrawing from these elections may also make late elections under ...