of the Revenue Reconciliation Act of 1990) shall apply for purposes of subsection (a). (f) Treatment of credit The amount of the credit determined under this section with respect to any qualified semiconductor equipment placed in service before January 1, 2027, or any qualified semiconductor manufacturing facility investment expenditures incurred before such date, shall be treated as a credit allowable under subpart C (and not allowable under section 38). (g) Denial of double benefit (1) Reduction of basis If a credit is determined under this section with respect to any property, the basis of such property shall be reduced by the amount of the credit so determined. (2) Other credits No credit shall be allowed under any provision of this chapter with respect to any amount taken in account in determining the credit allowed to a taxpayer under this section. (h) Rules relating to leased property For purposes of subsection (a)(3), rules similar to the rules under section 48(d) (as in effect on the day before the date of the enactment of the Revenue Reconciliation Act of 1990) shall apply. (i) Disallowance No credit shall be allowed under this section with respect to any qualified semiconductor equipment which is used predominantly outside the United States. (j) Partnerships In the case of a credit under subsection (a) which is determined at the partnership level, with respect to any partner which is exempt from taxation under section 501(a), such partner may elect to transfer their distributive share of such credit to any other partner in the partnership. (k) Regulations The Secretary shall prescribe such regulations or other guidance as may be necessary to carry out the purposes of this section, including any such measures as are deemed appropriate to avoid abuse or fraud with respect to the credit allowed under this section. . (b) Tax on base erosion payments of taxpayers with substantial gross receipts Section 59A(b)(1)(B)(ii) of the Internal Revenue Code of 1986 is amended— (1) in subclause (II), by striking the