@Carl Sorry, but almost everything you said was wrong.
Although you are right that the improvement to the residential property itself would not qualify for §179, assets inside of it (such as appliances) may qualify in certain circumstances.
The Special Depreciation Allowance is 100%, not 50%.
If your income is under $150,000, you certainly CAN use at least part of the loss, and some rentals DO operate at a profit. It is irresponsible to tell people it won't make a difference on their tax return when in MANY cases it WILL reduce their current year taxes. Just because your income is high enough that you can't use the loss doesn't mean that every landlord's income is over $150,000.
And the De Minimis Safe Harbor DOES apply to the improvements to the permanent and physical part of the real estate (*IF* they otherwise qualify for the De Minimis Election and they actually make that election). There is no restriction in that regard against for real estate.
