Based on the uploaded IRS press release IR-2026-06 (dated January 14, 2026), here are the key provisions of Notice 2026-11 regarding bonus depreciation changes enacted by the One, Big, Beautiful Bill Act (OBBBA):

Key Changes

✅ Permanent 100% Bonus Depreciation

• Applies to qualified depreciable property acquired after January 19, 2025
• Eliminates the previous phase-down schedule that would have reduced bonus depreciation to 40% for 2025 property
• Also applies to specified plants planted or grafted after January 19, 2025

✅ New Election Options
Taxpayers may elect to:

• Claim only 40% (or 60% for long-production property/aircraft) instead of 100% bonus depreciation for property placed in service during their first tax year ending after January 19, 2025
• Deduct bonus depreciation for specified plants
• Treat components of larger self-constructed property as separately eligible for bonus depreciation
• Opt out of bonus depreciation for qualified sound recording productions

✅ Sound Recording Productions Now Eligible

• Qualified sound recordings are now treated as depreciable property eligible for bonus depreciation
• Acquisition date: Date principal recording commences
• Placed in service: Date of initial release or broadcast
• Eligible if production commences in taxable years ending after July 4, 2025 (date of OBBBA enactment)

Practical Implications

• Taxpayers can generally rely on existing §168(k) regulations with modifications reflecting the permanent 100% rate
• The guidance provides interim rules until formal regulations are issued
• Taxpayers should carefully evaluate whether to claim 100% bonus depreciation or elect the reduced 40%/60% rate for property placed in service in their first tax year after January 19, 2025 (potentially for cash flow or AMT planning reasons)