Manufacturers of semiconductors and semiconductor manufacturing equipment in the United States may achieve significant tax savings from Internal Revenue Code (IRC) Section 48D, the advanced manufacturing investment tax credit.
Established by the Creating Helpful Incentives to Produce Semiconductors and Science Act, commonly referred to as the CHIPS act, the Section 48D credit is based on certain criteria related to the types of property used in the manufacturing process.
One important factor in determining eligibility for the credit is identifying the components of the building used in the manufacturing process. An engineering-based cost segregation study can be a valuable tool in identifying these components.
Advanced manufacturing investment tax credit
The advanced manufacturing investment tax credit provides a federal income tax credit of up to 25% of the investment in qualified property placed into service by the taxpayer during the taxable year beginning on or after Jan. 1, 2023, or for which construction begins on or before Dec. 31, 2026.
Qualified property includes:
- Facilities dedicated to manufacturing semiconductors or related equipment
- Tangible property like buildings or structural components integral to operation
Some exceptions include buildings or portions thereof used for offices, administrative services, or other nonmanufacturing functions.
Additionally, any advanced manufacturing expenditures attributable to qualified rehabilitation as defined in IRC Section 47(c)(2) wouldn’t be eligible.
One important factor in determining eligibility for the investment tax credit is identifying the components of the building used in the manufacturing process. This can be a complex task, as many building components may have multiple uses and it may be difficult to determine which components are specifically used in the manufacturing process.
Benefits of a cost segregation study in identifying eligible components
A cost segregation study is a method of identifying the components of a building that can be depreciated over shorter periods of time than the building itself.
The information provided here is of a general nature and is not intended to address the specific circumstances of any individual or entity. In specific circumstances, the services of a professional should be sought. Tax information, if any, contained in this communication was not intended or written to be used by any person for the purpose of avoiding penalties, nor should such information be construed as an opinion upon which any person may rely. The intended recipients of this communication and any attachments are not subject to any limitation on the disclosure of the tax treatment or tax structure of any transaction or matter that is the subject of this communication and any attachments.


