What Clean Energy Companies Need To Know About New IRS Rules on Foreign Entity Restrictions

On February 12, 2026, the Treasury Department and the IRS released Notice 2026-15 (the “Notice”), providing long-awaited interim guidance on the “material assistance from a prohibited foreign entity” (PFE) restrictions enacted under the One Big Beautiful Bill Act (OBBBA). In practical terms, these new rules determine whether your clean energy project or manufactured component qualifies for valuable federal tax credits. If your supply chain includes materials or assistance from certain foreign... By: Snell & Wilmer