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