This notice provides that, pending the resolution of a number of legal and factual issues, the IRS will not challenge a taxpayer’s position that the Puerto Rican excise tax is a tax in lieu of an income tax under section 903 of the Code.

This procedure provides guidance with respect to the 100-percent additional first year depreciation deduction under sections 168(k)(5) of the Code, and the extension of the 50-percent bonus depreciation deduction for qualified property placed in service in 2010. This procedure defines which property is eligible for the 100-percent bonus depreciation deduction and provides guidance regarding the time and manner for making certain elections under sections 168(k)(2) and (5). The procedure also provides a safe harbor method of accounting for passenger automobiles that qualify for the 100-percent additional first year depreciation deduction and that are subject to first-year limitations under section 280F. Rev. Proc. 2011-21 amplified.