CHIPS Direct Pay Rules Offer New Opportunities for Partnerships

June 20, 2023, 8:45 AM UTC

The IRS and Treasury’s proposed rules on a tax credit included in the CHIPS Act are favorable for partnerships and S corporations interested in starting chip manufacturing projects, tax practitioners say.

The rules, released last week, allow pass-throughs to receive a direct payment for the advanced manufacturing investment credit at the entity level, including companies that have both active and passive investors. Normally, pass-throughs with passive investors wouldn’t be allowed to receive the benefits of tax credits due to long-standing passive activity loss rules in the US tax code.

More inclusive rules will bring into the fold larger investment ...

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