Verdex

FEOC screening · 45X · 45Y · 48E

Is your supplier a Prohibited Foreign Entity (PFE)?

Type a company’s name. We check the federal lists, then who owns it, who controls it and who lends to it.

Automated screening. Not reviewed. For a verdict you can file, order the reviewed report.

The rule

A prohibited foreign entity cannot claim 45X, 45Y or 48E. A facility or component also fails when too much of its cost comes from one.

IRC §7701(a)(51) and (52) →

The tests

Held from a covered nation, at or above

  • One owner25%
  • Owners together40%
  • Lenders15% of debt

Or any one of

  • Federal list
  • State-owned
  • Board seat
  • Licensing

Any one of these makes a supplier a prohibited foreign entity.

The 25% threshold, explained →

The record

A signed certificate is the supplier’s word. Whether the credit survives depends on what the registries say.

§6695B and the certification →

The outcome

A verdict for the compliance file, with every finding sourced and reviewed.

The four verdicts

supplier legal name

FEOC Compliance Screening Report · Example

Prepared for · Supplier screen, run cold from public and registry records · Screening ID VX-0000

Executive Summary CAUTION

Overall Disposition: CAUTION.

Lists CLEAROwnership CAUTIONControl CLEARDebt CAUTIONCertification CAUTION

Scope: the supplier as registered, its owners to the ultimate parent, its lenders, and its supplier certification.

  • What matters. The registry shows a holding company in a third country above the supplier. Who owns the holding company is not in the public record.
  • What it does not establish. No list match. No covered-nation owner found. No covered-nation lender found.
  • What closes it. The holding company’s shareholder register, and the supplier’s signed certification with every statutory field.

Next steps

  1. Request the shareholder register from the supplier.
  2. Collect the certification with every statutory field.
  3. Re-screen when both arrive.
CLEAR: No list match, no foreign-influence indicator. Ownership and control outside covered nations.
CAUTION: Record incomplete. No conclusion either way. The closing documents are named.
FLAGGED: A specific adverse indicator, documented, with its resolution path.
BLOCKED: Covered-nation headquarters or ownership, or a statutory-list match.

Prepared to support the client’s FEOC compliance documentation under IRC §7701(a)(51) and (52). Final legal and tax determinations remain with counsel. Pages 2 to 5: entity profile, list check, ownership, control, debt, certification, recommended actions, methodology, source citations.

Page one, as it prints. The supplier is an example.

Order a screening report.

Send the list. Get a verdict on each.

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