Foreign Entity of Concern

Navigating Prohibited Foreign Entity Restrictions in Clean Energy Tax Credits: An Analysis of IRS Notice 2026-15

February 15, 2026February 13, 2026 by Julie Chesna

Executive Summary The One, Big, Beautiful Bill Act, which is commonly known as OBBBA and was enacted on July 4, 2025, introduced significant restrictions on clean energy tax credits under Internal Revenue Code Sections 45X, 45Y, and 48E to limit involvement from Prohibited Foreign Entities, or PFEs. IRS Notice 2026-15 provides interim guidance on these … Read more

The New FEOC Rules for Section 48E: Implications for Clean Energy Investments Under the One Big Beautiful Bill Act

August 18, 2025July 21, 2025 by Julie Chesna

By: Josh Howes, CEO Executive Summary The Clean Electricity Investment Tax Credit under Section 48E of the Internal Revenue Code (IRC) represents a pivotal incentive for advancing zero-emission electricity generation and energy storage technologies in the United States. However, the recently enacted One Big Beautiful Bill Act (OBBBA), signed into law on July 7, 2025, … Read more

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