Regulatory Intelligence

FEOC Resources

Essential guidance on Foreign Entity of Concern rules for clean energy tax credits. 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 45X tax credits?

Three core prohibitions apply to Section 45X Advanced Manufacturing credits:

(A) Ownership — You cannot claim 45X if classified as a PFE, effective for tax years after July 4, 2025.

(B) Material Assistance (MACR) — Manufacturers cannot receive assistance from PFEs above component-specific thresholds that escalate annually. Battery: 60% in 2026 → 85% by 2030+. Solar: 50% in 2026 → 85% by 2030+.

(C) Effective Control — No credit for components produced under effective control by an SFE.

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.

What is a Prohibited Foreign Entity?

The difference between Specified Foreign Entities (SFE) and Foreign-Influenced Entities (FIE), and why both land you at the same cliff.

Structural Risk

The 25% Ownership Threshold

Navigating the mathematics of Foreign-Influenced Entities — where a single licensing clause can contaminate an entire supply chain.

§6695B and the New Attestation Liability

Why blind trust in supplier statements is no longer an adequate defense, and what your attestation package needs to contain.

In the News

DECERN

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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