IRS Issues Interim Guidance on “Material Assistance” from a Prohibited Foreign Entity

On February 12, 2026, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) released Notice 2026-15 (the “Notice”), providing long-awaited interim guidance on the restrictions on receiving “material assistance” from a prohibited foreign entity (“PFE”) that were enacted by the One Big Beautiful Bill Act (the “OBBBA”). The Notice provides important clarifications to the application of the “material assistance” requirement which generally can disqualify a taxpayer... By: Mayer Brown