Resources · 45X · 45Y · 48E

Reading on FEOC

Four guides with primary-source citations, the dates the rules turn on, the news, and the framework in questions.

Guides

Timeline

  1. Jul 4, 2025 FEOC

    Ownership prohibition takes effect

    No §45X, §45Y or §48E credit for a taxpayer that is itself a prohibited foreign entity, for tax years after this date. §45X material-assistance limits apply to components sold after it.

  2. Dec 31, 2025 FEOC

    Facilities beginning construction after this date

    The §45Y and §48E material-assistance thresholds apply to qualified facilities and storage that begin construction after this date.

  3. 2026 FEOC

    First-year thresholds

    Material-assistance cost ratios start at 50% for solar components and 60% for battery components under §45X, 40% for qualified facilities and 55% for storage under §45Y and §48E, and rise every year to 2030.

  4. Feb 12, 2026 FEOC

    IRS Notice 2026-15

    The first substantive guidance on how prohibited-foreign-entity restrictions work: calculation mechanics, certifications, what is still open.

  5. Dec 31, 2026 FEOC

    Safe-harbor tables due

    The IRS is to publish the safe-harbor tables for the material-assistance cost ratio by this date.

  6. Dec 23, 2027 CHIPS

    Federal procurement ban on named chip makers

    Under the FY23 NDAA §5949, federal procurement of semiconductors from the named manufacturers is barred from this date.

  7. 2030 FEOC

    Thresholds reach their ceiling

    Material-assistance cost ratios reach 85% for §45X components and keep rising for facilities, after which they hold.

In the news

The framework, in questions

What are the FEOC requirements for clean energy tax credits?

How do I determine if a supplier is a Foreign Entity of Concern?

What is the Material Assistance Cost Ratio (MACR)?

What does §6695B change about my personal liability?

How do the new PFE rules differ from the old FEOC rules?

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