American Public Power Association filed 1 comment on this docket between Jun 15, 2026 and Jun 15, 2026. 3 other organizations filed here. The comment window closed 120d ago.
On behalf of the American Public Power Association, please find attached our comments in relation to Prohibited Foreign Entity Guidance as requested in IRS Notice 2026-15.
Notice 2026-15 provides guidance under §§ 45X, 45Y, and 48E of the Internal Revenue Code (Code) for determining a qualified facility’s, energy storage technology’s, or eligible component’s material assistance cost ratio (MACR) for purposes of determining whether there was material assistance from a prohibited foreign entity (PFE). This notice also provides limited general guidance related to the definition of a PFE and requests comments regarding definitional, anti-circumvention, and other issues for future guidance.
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