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New tax code section 7701 (a) (51) provides, simply, “the term ‘prohibited foreign entity’ means a specified foreign entity or a foreign influenced entity.” (emphasis added.) The obbba introduced several new entity categories, all under the umbrella term “prohibited foreign entity” (pfe), which are barred from obtaining clean energy tax credits. The determination as to whether an entity is a prohibited foreign entity is made as of the last day of such tax year
However, for the first tax year after july 4, 2025, the determination related to specified foreign entity (other than foreign controlled entity) status is made as of the first day of the tax year. The restrictions could apply to the entire supply chain to affect the components, finished products and facilities. Obbba introduces new “prohibited foreign entity” (pfe) rules for certain clean energy credits
The most extensive pfe rules apply to the clean electricity production tax credit (45y), the clean electricity investment tax credit (48e), and the advanced manufacturing production tax credit (45x).
A borrower entity could be deemed a foreign influenced entity if 15 percent or more of its debt is held by a specified foreign entity See §7701 (a) (51) (d) (i) (i) (dd) 1 being a foreign influenced entity would mean that projects owned by that entity would not qualify for certain energy tax credits. Our focus here is on h.r
New restrictions under the obbb limit eligibility for u.s Energy tax credits for entities linked to prohibited foreign entities, requiring careful review of ownership, debt, and supply chain relationships Minority investments or contracts with prohibited foreign entities can affect tax credit eligibility, even without majority ownership Foreign entity of concern rules in the obbba expand clean energy tax credit restrictions, reshaping eligibility and compliance starting in 2026.
Sections 45x and 48e contain similar limitations
21 we now turn to the definition of material assistance Material assistance the obbba establishes a new overarching definition under paragraph (52) of tax code section 7701 (a) It provides, in subparagraph (a), that the term “material assistance from a prohibited foreign entity” means: The one big beautiful bill act (obbba), enacted july 4, marks a turning point in the federal government’s approach to clean energy tax policy
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