by striking 50 percent and inserting 100 percent . (b) Made permanent Section 168(k)(2) of the Internal Revenue Code of 1986 is amended to read as follows: (2) Qualified property For purposes of this subsection— (A) In general The term qualified property means property— (i) (I) to which this section applies which has a recovery period of 20 years or less, (II) which is computer software (as defined in section 167(f)(1)(B)) for which a deduction is allowable under section 167(a) without regard to this subsection, (III) which is water utility property, or (IV) which is qualified leasehold improvement property, and (ii) the original use of which commences with the taxpayer. (B) Exception for alternative depreciation property The term qualified property shall not include any property to which the alternative depreciation system under subsection (g) applies, determined— (i) without regard to paragraph (7) of subsection (g) (relating to election to have system apply), and (ii) after application of section 280F(b) (relating to listed property with limited business use). (C) Special rules (i) Sale-leasebacks For purposes of clause (ii) and subparagraph (A)(ii), if property is— (I) originally placed in service by a person, and (II) sold and leased back by such person within 3 months after the date such property was originally placed in service, such property shall be treated as originally placed in service not earlier than the date on which such property is used under the leaseback referred to in subclause (II). (ii) Syndication For purposes of subparagraph (A)(ii), if— (I) property is originally placed in service by the lessor of such property, (II) such property is sold by such lessor or any subsequent purchaser within 3 months after the date such property was originally placed in service (or, in the case of multiple units of property subject to the same lease, within 3 months after the date the final unit is placed in service, so long as the period between the time the first unit is placed in service and the time the