About this episode

This episode discusses the impact of FEOC rules and energy tax credits on investment strategies in the energy sector.

Foreign Entity of Concern, or FEOC, rules and energy tax credits are reshaping how companies evaluate eligibility and structure investments across the energy sector. In this episode, we explore how the foreign entity of concern framework—introduced under the One Big Beautiful Bill Act—applies at both the taxpayer and project level across the energy sector. We cover recent IRS and Treasury guidance and highlight practical challenges related to supply chain tracing, compliance, and financing.&n...

Topics covered

• sustainability
• energy tax credits
• foreign entity of concern
• investment structure
• IRS guidance
• compliance challenges

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