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Moe Worsley

Moe Worsley is a partner in the Firm's San Francisco/Palo Alto office and a member of the North America Tax Practice Group. Mr. Worsley primarily advises US and multinational enterprises on domestic and cross-border taxation matters. He has a broad range of experience in advising on US and international tax planning matters, in particular, post acquisition integrations, and structuring and implementing international operations, as well as cross-border mergers, acquisitions and dispositions. Mr. Worsley has advised on tax matters related to a domestic and cross-border transactions for a variety of public and private sectors including technology companies, travel companies, financial institutions (including banks and insurance companies), pharmaceutical and healthcare companies, private equity funds, governmental bodies and telecommunications companies.

On 5 March 2024, Treasury and the IRS published Treas. Reg. § 1.48D-6 (“Final Regulations”), which implements the section 48D(d) election allowing eligible taxpayers to treat the amount of the advanced manufacturing investment credit (“CHIPs Credit”) established under the Creating Helpful Incentives to Produce Semiconductors Act of 2022 as a payment against Federal income tax liabilities, i.e., a “direct pay election” For eligible taxpayers seeking to treat the CHIPs Credit allowed in any tax year as a payment against Federal income tax liabilities in lieu of claiming the credit, the Final Regulations generally retain the structure and framework for administering the election laid out in proposed and temporary regulations, with welcome modifications to clarify key issues relating to the limitations for making the elective payments, the ‘denial of double benefits’ rule, and the election’s pre-filing requirements.