IRS Notice 2026-15 & Detailed FEOC Guidance

The Internal Revenue Service (the “IRS” or “Service”) recently released detailed guidance concerning the classification and treatment of Prohibited Foreign Entities (“PFEs”) as well as the application of the related Foreign Entity of Concern (“FEOC”) restrictions that were created in the One Big Beautiful Bill Act (“OBBBA” or “Bill”).... By: Husch Blackwell LLP