On March 23, 2023, the Department of the Treasury and the Internal Revenue Service (IRS) published a proposed rule for the Advanced Manufacturing Investment Credit (CHIPS ITC) established by the CHIPS Act of 2022. The proposal addresses the credit's eligibility requirements, an election that eligible taxpayers may make to be treated as making a payment of tax (including an overpayment of tax), or for an eligible partnership or S corporation to receive an elective payment, instead of claiming a credit, and a special 10-year credit recapture rule that applies if there is a significant transaction involving the material expansion of semiconductor manufacturing capacity in a foreign country of concern.