@Carl With all due respect, what you wrote in your post, as pointed out by @Anonymous, is still erroneous. Beyond the special allowance, however, the two criteria you posted that must be met to be "classified as an improvement" are not incorporated into the Code, Regs, Rulings, Publications, case law, or any source that could be considered even remotely authoritative.
If you do not want to mention the $25,000 special allowance (for whatever reason), then you should also not flatly state, "Once your rental expenses get your taxable rental income to zero, that's it. You can't deduct any more.", because that is simply inaccurate depending upon the individual taxpayer's circumstances.
Further, it needs to be pointed out (although it should not need to be pointed out) that virtually none of us have even a rough idea as to how many taxpayers will "still have carry over", much less do we know that "about half the folks" will have carryover. Frankly, if a qualifying rental owner continually sustained more than $25,000 in net losses, I would advise that owner to consider selling the rental property.
