Knowledge base
Resources
Knowledge Base
Resources
FEOC compliance and supply-chain intelligence. Plain-language explainers, primary-source citations, and the news we're tracking.
FEOC Compliance Framework
The critical information you need to navigate the Foreign Entity of Concern regulations.
What are the FEOC requirements for clean energy tax credits?
Three core prohibitions apply to §45Y, §48E, and §45X clean energy credits:
(A) Ownership — No credit under 45X, 45Y, or 48E if the taxpayer itself is classified as a PFE, effective for tax years after July 4, 2025.
(B) Material Assistance (MACR) — Credits are denied if a project or component receives material assistance from a PFE above applicable thresholds. Effective dates differ: 45X applies to eligible components sold in tax years after July 4, 2025; 45Y/48E applies to facilities beginning construction after December 31, 2025.
45X component thresholds: Battery: 60% in 2026 → 85% by 2030+. Solar: 50% in 2026 → 85% by 2030+.
45Y/48E facility thresholds: Qualified facilities: 40% in 2026 (escalating annually). Energy storage: 55% in 2026 (escalating annually).
(C) Effective Control — No credit for projects or components produced under effective control by an SFE. §48E adds a 10-year, 100% recapture provision for post-placement violations.
(A) Ownership — No credit under 45X, 45Y, or 48E if the taxpayer itself is classified as a PFE, effective for tax years after July 4, 2025.
(B) Material Assistance (MACR) — Credits are denied if a project or component receives material assistance from a PFE above applicable thresholds. Effective dates differ: 45X applies to eligible components sold in tax years after July 4, 2025; 45Y/48E applies to facilities beginning construction after December 31, 2025.
45X component thresholds: Battery: 60% in 2026 → 85% by 2030+. Solar: 50% in 2026 → 85% by 2030+.
45Y/48E facility thresholds: Qualified facilities: 40% in 2026 (escalating annually). Energy storage: 55% in 2026 (escalating annually).
(C) Effective Control — No credit for projects or components produced under effective control by an SFE. §48E adds a 10-year, 100% recapture provision for post-placement violations.
What is the Material Assistance Cost Ratio (MACR)?
How do the new PFE rules differ from the old FEOC rules?
How do I determine if a supplier is a Foreign Entity of Concern?
What does §6695B change about my personal liability?
What are the FEOC requirements for clean energy tax credits?
Three core prohibitions apply to §45Y, §48E, and §45X clean energy credits:
(A) Ownership — No credit under 45X, 45Y, or 48E if the taxpayer itself is classified as a PFE, effective for tax years after July 4, 2025.
(B) Material Assistance (MACR) — Credits are denied if a project or component receives material assistance from a PFE above applicable thresholds. Effective dates differ: 45X applies to eligible components sold in tax years after July 4, 2025; 45Y/48E applies to facilities beginning construction after December 31, 2025.
45X component thresholds: Battery: 60% in 2026 → 85% by 2030+. Solar: 50% in 2026 → 85% by 2030+.
45Y/48E facility thresholds: Qualified facilities: 40% in 2026 (escalating annually). Energy storage: 55% in 2026 (escalating annually).
(C) Effective Control — No credit for projects or components produced under effective control by an SFE. §48E adds a 10-year, 100% recapture provision for post-placement violations.
(A) Ownership — No credit under 45X, 45Y, or 48E if the taxpayer itself is classified as a PFE, effective for tax years after July 4, 2025.
(B) Material Assistance (MACR) — Credits are denied if a project or component receives material assistance from a PFE above applicable thresholds. Effective dates differ: 45X applies to eligible components sold in tax years after July 4, 2025; 45Y/48E applies to facilities beginning construction after December 31, 2025.
45X component thresholds: Battery: 60% in 2026 → 85% by 2030+. Solar: 50% in 2026 → 85% by 2030+.
45Y/48E facility thresholds: Qualified facilities: 40% in 2026 (escalating annually). Energy storage: 55% in 2026 (escalating annually).
(C) Effective Control — No credit for projects or components produced under effective control by an SFE. §48E adds a 10-year, 100% recapture provision for post-placement violations.
How do I determine if a supplier is a Foreign Entity of Concern?
What is the Material Assistance Cost Ratio (MACR)?
What does §6695B change about my personal liability?
How do the new PFE rules differ from the old FEOC rules?
Key Concepts
FEOC Explainers
Core regulatory concepts broken down in plain language.
In the News
VERDEX
Recent Updates to FEOC Compliance Based on IRS Notice 2026-15
Feb 2026
HOLLAND & KNIGHT
Treasury Department and IRS Release Prohibited Foreign Entity Guidance
Feb 12, 2026
UTILITY DIVE
Clean energy industry preps ahead of impending FEOC guidance
Dec 13, 2025
POWER MAGAZINE
Welcome to the Jungle: We Got FEOC (and Games)
Nov 2025
K&L GATES
Understanding the New Prohibited Foreign Entity Rules
Sep 18, 2025
HOLLAND & KNIGHT
Foreign Entity Rules Begin to Shape Clean Energy Deals
Sep 2025
PV MAGAZINE
The 'onion' of FEOC, Safe Harbor, and tax credits
Aug 27, 2025
NORTON ROSE FULBRIGHT
Working Through The FEOC Maze
Jul 8, 2025
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