Treasury Weighs Energy Tax Credit Foreign Restriction Concerns

Tax attorney Amish Shah was mentioned in a Bloomberg Tax article about the U.S. Department of the Treasury's efforts to address taxpayer questions regarding new foreign entity of concern (FEOC) restrictions added to energy tax credits under the 2025 One Big Beautiful Bill Act. The article reported that Treasury officials expect forthcoming guidance to clarify key definitions, due diligence expectations for determining whether components or contract payments have ties to prohibited foreign entities and how domestic content safe harbor tables may apply in this context. Mr. Shah noted that uncertainty around these restrictions is already influencing business decisions, including restructuring to preserve eligibility for the credits before guidance is issued.

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