The Internal Revenue Service (IRS) has released interim guidance in Notice 2026-16, outlining a major new tax incentive for the manufacturing sector. The guidance implements a 100% special depreciation allowance under IRC §168(n) for certain commercial real property classified as Qualified Production Property (QPP).

This provision—enacted as part of the One Big Beautiful Bill Act (OBBBA)—allows businesses to immediately deduct the full cost of qualifying production facilities in the year they are placed in service. For companies planning to expand U.S. manufacturing operations, this represents a significant tax planning opportunity.

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IRS Issues Guidance on 100% Depreciation for Commercial Real Estate – Withum