IRS guidance (Notice 2026-15) provides interim rules and safe harbors to be published as future proposed regulations for determining whether a clean energy facility, energy storage technology (EST), or an eligible component includes “material assistance from a prohibited foreign entity” (PFE). If a PFE is involved or found in the supply chain, then a material assistance cost ratio (MACR) analysis is required and credits under Sec. 45Y (clean electricity production), Sec. 48E (clean electricity investment), or Sec. 45X (advanced manufacturing) may be disallowed. Notice 2026-15 provides interim computational rules for the MACR and allows taxpayer reliance until 60 days after forthcoming proposed regulations and safe-harbor tables are published. Taxpayers claiming these credits must now evaluate complex ownership, sourcing, and supply chain factors to ensure compliance.

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