Restrictions to certain energy credits with respect to status, and sourcing from, a prohibited foreign entity

 

Notice 2026-15 provides interim guidance implementing statutory restrictions that limit eligibility for certain clean-energy tax credits determined on Form 3468, Form 7207, and Form 7211. These restrictions were enacted by P.L. 119-21, commonly known as the One Big Beautiful Bill Act. The notice describes safe harbors for purposes of determining a taxpayer's material assistance from prohibited foreign entities, and provides other prohibited foreign entity guidance. See Notice 2026-15 for more information.