Summary of Notice 2026-15: FEOC Guidance
Attached is Capitol Tax Partners' summary of Notice 2026-15: Guidance to Apply Interim Safe Harbors for Purposes of Determining a Taxpayer’s Material Assistance from a Prohibited Foreign Entity; Other Prohibited Foreign Entity Guidance.
The Notice issued on February 12 provides certain safe harbors and other implementing guidance related to the Foreign Entity of Concern (FEOC) restrictions applicable to energy tax credits as enacted by the One Big Beautiful Bill Act (P.L. 119-21).