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139 STAT. 200 PUBLIC LAW 119–21—JULY 4, 2025 ‘‘(A) OTHER SPECIAL DEPRECIATION ALLOWANCES.—For purposes of subsections (k)(7), (l)(3)(D), and (m)(2)(B)(iii)— ‘‘(i) qualified production property shall be treated as a separate class of property, and ‘‘(ii) the taxpayer shall be treated as having made an election under such subsections with respect to such class. ‘‘(B) ALTERNATIVE DEPRECIATION PROPERTY.—The term ‘qualified production property’ shall not include any prop- erty to which the alternative depreciation system under subsection (g) applies. For purposes of subsection (g)(7)(A), qualified production property to which this subsection applies shall be treated as separate nonresidential real property. ‘‘(5) RECAPTURE.—If, at any time during the 10-year period beginning on the date that any qualified production property is placed in service by the taxpayer, such property ceases to be used as described in paragraph (2)(A)(ii) and is used by the taxpayer in a productive use not described in paragraph (2)(A)(ii)— ‘‘(A) section 1245 shall be applied— ‘‘(i) by treating such property as having been dis- posed of by the taxpayer as of the first time such property is so used in a productive use not described in paragraph (2)(A)(ii), and ‘‘(ii) by treating the amount described in subpara- graph (B) of section 1245(a)(1) with respect to such disposition as being not less than the amount described in subparagraph (A) of such section, and ‘‘(B) the basis of the taxpayer in such property, and the taxpayer’s allowance for depreciation with respect to such property, shall be appropriately adjusted to take into account amounts recognized by reason of subparagraph (A). ‘‘(6) ELECTION.— ‘‘(A) IN GENERAL.—An election under this subsection for any taxable year shall— ‘‘(i) specify the nonresidential real property subject to the election and the portion of such property des- ignated under paragraph (2)(A)(vi), and ‘‘(ii) except as otherwise provided by the Secretary, be made on the taxpayer’s return of the tax imposed by this chapter for the taxable year. Such election shall be made in such manner as the Sec- retary may prescribe by regulations or other guidance. ‘‘(B) ELECTION.—Any election made under this sub- section, and any specification contained in any such elec- tion, may not be revoked except with the consent of the Secretary (and the Secretary shall provide such consent only in extraordinary circumstances). ‘‘(7) REGULATIONS.—The Secretary shall issue such regula- tions or other guidance as may be necessary or appropriate to carry out the purposes of this subsection, including regula- tions or other guidance— ‘‘(A) providing rules for regarding what constitutes substantial transformation of property which are consistent with guidance provided under section 954(d), and Guidance. Adjustment. Applicability. Time period. Applicability.