IRS Notice 2026-15 introduces interim guidance and restrictions on specific clean-energy tax credits, including those claimed on Forms 3468, 7207, and 7211. These restrictions, enacted by P.L. 119-21 (the One Big Beautiful Bill Act), limit eligibility for taxpayers receiving material assistance from or sourcing from prohibited foreign entities. The notice outlines safe harbors for determining such assistance and provides further guidance on identifying prohibited foreign entities.

Companies seeking clean-energy tax credits must review their relationships with foreign entities to ensure compliance with these new restrictions. Taxpayers need to assess whether they receive material assistance from or source materials from prohibited foreign entities, utilizing the safe harbors provided in the notice to determine eligibility. Failure to comply may result in the denial of these credits. The guidance is effective upon publication, with specific compliance actions required to maintain eligibility.