Tiber Creek’s Energy Spotlight: Interim FEOC/PFE Guidance

On Feb. 12, the Treasury Department and Internal Revenue Service (IRS) released their long-awaited interim guidance on prohibited foreign entities (PFEs) and safe harbors.

This brief explainer breaks down the new PFE guidance and what it means for eligibility under 45Y, 48E, and 45X. Click here to understand how the material assistance cost ratio (MACR), the PFE test, and supplier certifications fit together — and what actions may be required.

See Treasury’s announcement here and the notice here.

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