INCOME TAX

REG-101607-23, page 1127. This item contains proposed regulations concerning the election under the Inflation Reduction Act of 2022 to treat the amount of certain tax credits as a payment of Federal income tax. The proposed regulations describe rules for the elective payment of these credit amounts in a taxable year, including definitions and special rules applicable to partnerships and S corporations and regarding repayment of excessive payments. In addition, the proposed regulations describe rules related to an IRS pre-filing registration process that would be required. These proposed regulations affect tax-exempt organizations, State and local governments, Indian tribal governments, Alaska Native Corporations, the Tennessee Valley Authority, rural electric cooperatives, and, in the case of three of these credits, certain taxpayers eligible to elect the elective payment of credit amounts in a taxable year. This document also provides notice of a public hearing on the proposed regulations.

REG-101610-23, page 1161. This item contains proposed regulations concerning the election under the Inflation Reduction Act of 2022 to

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transfer certain Federal income tax credits. The proposed regulations describe the proposed rules for the election to transfer eligible credits in a taxable year, including definitions and special rules applicable to partnerships and S corporations and regarding excessive credit transfer or recapture events. In addition, the proposed regulations describe rules related to an IRS pre-filing registration process that would be required. These proposed regulations affect eligible taxpayers that elect to transfer eligible credits in a taxable year and the transferee taxpayers to which eligible credits are transferred.

REG-105595-23, page 1194. These proposed regulations provide guidance regarding the elective payment election of the advanced manufacturing investment credit under section 48D of the Internal Revenue Code (Code). The proposed regulations reflect changes made by the CHIPS Act of 2022, and supplement the rules proposed in the March 2023 proposed regulations. The section 48D credit may be claimed for qualified investments in an advanced manufacturing facility that manufactures finished semiconductors or finished semiconductor manufacturing equipment.