Currents Podcast

Project finance, renewable energy and more

Ep335: New IRS Guidance on FEOC and 45Z Tax Credits

February 19, 2026 | By Todd Alexander in New York and Keith Martin in Washington, DC

Keith Martin, Norton Rose Fulbright partner, discusses newly issued IRS guidance on the FEOC rules, explaining how the Treasury clarified the calculation of prohibited foreign content and what uncertainty remains for developers and tax credit buyers. He also reviews proposed regulations for the 45Z clean fuel tax credit and how the changes may improve transferability and market participation.

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Ep335: New IRS Guidance on FEOC and 45Z Tax Credits

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