Guidance to Apply Interim Safe Harbors for Purposes of Determining a Taxpayer’s Material Assistance from a Prohibited Foreign Entity; Other Prohibited Foreign Entity Guidance (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.