On 27 November 2018, the U.S. IRS has issued Revenue Procedure 2018-59, which provides an infrastructure safe harbor that allows taxpayers to treat certain infrastructure trades or businesses as real property trades or businesses solely for purposes of qualifying as an electing real property trade or business under section 163(j). Section 163(j) generally provides that for taxable years beginning after 31 December 2017, the deduction for interest expense for a trade or businesses is limited to the sum of business interest income for the year, plus 30% of adjusted taxable income, plus floor plan financing interest. However, certain exemptions apply,...