Clean Energy Market Stalled on Foreign Entity Guidance, Tax Notes

Partner Casey August was quoted by Tax Notes in an article examining ongoing uncertainty surrounding the One Big Beautiful Bill Act’s prohibited foreign entity provisions and their impact on clean energy tax credit transactions.

Casey highlighted the challenges taxpayers face in applying the new rules, particularly as they seek to assess eligibility for clean energy credits while awaiting additional guidance from the US Department of the Treasury and the Internal Revenue Service.

He noted that the foreign entity of concern provisions are “the most pervasive question” that has “really kind of held up some aspects of the market until we receive guidance.”

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