The South Carolina textile mill credit has changed several times since first enacted under Chapter 65 of Title 12 back in 2008. (And four years before that there was a prior version under Chapter 32 of Title 6!) Having worked on dozens of SC textile mill deals over the last twenty years, The Sherbert Group has learned that the specific fact-pattern of a given property needs to be closely analyzed to understand how eligibility for the credit may be impacted.
Though the SC Department of Revenue issued a revenue ruling in 2015 that answered a number of questions, subsequent amendments to the code have made interpreting that ruling rather difficult. Last year, the DOR decided to address some of these changes, and the result is the publication of SC Revenue Ruling #25-1. It was issued on February 10, 2025, but was revised later in the month to add specifics for the effective date of the ruling and the outside date to potentially revise a Notice of Intent to Rehabilitate.
This new ruling supersedes the one from 2015, and applies to projects for which the Notice of Intent is filed after February 10, 2025. Some provisions of the prior ruling have been left behind, and there is a lot of new information here. Overall, the new ruling should help to clarify things for many projects in relation to the current textile statute. Most notably, the new ruling addresses parcels contiguous to a mill site that may be eligible for the credit, a very important change as the contiguous parcel provision was only added after 2015.
This ruling adds a new layer to the analysis of how a given property fits within the textile statute. If you’re currently looking at a mill redevelopment in South Carolina – or something contiguous to a mill site – The Sherbert Group would be glad to take a look to see how the credit might benefit you.
Aaron Mayer
Director of Sherbert Consulting and Moxie Investment Funds
704-926-8167