Estate
(iii) Estate or trust. The basis of qualified property that is part of an advanced manufacturing facility of an eligible taxpayer and placed in service during the taxable year by an estate or trust must be apportioned among the estate or trust and its beneficiaries on the basis of the income of the estate or trust allocable to each for that taxable year. (3) Qualified progress expenditures election(i) In general. A taxpayer may elect, as provided in 1.46-5, to increase the qualified investment with respect to any advanced manufacturing facility of an eligible taxpayer for the taxable year, by any qualified progress expenditures made after August 9, 2022. (ii) Special rules for certain passthrough entities. Notwithstanding the provisions of 1.46-5, relating to elections of progress expenditure property being constructed by or for a partnership or S corporation, the rules of 1.46-5(o)(1) and (p) do not apply to prohibit a partnership or S corporation from making a progress expenditure election under 1.46-5 with respect to qualified property if the partnership or S corporation intends to make an elective payment election under section 48D(d) and 1.48D-6 with respect to a section 48D credit determined with respect to such qualified property. (4) Examples. The provisions of this paragraph (j) are illustrated by the following examples.