"Understanding the New Prohibited Foreign Entity Rules for Clean Energy," Davis Wright Tremaine & Lexology webinar
The One Big Beautiful Bill Act introduces sweeping changes to the Internal Revenue Code's clean energy tax provisions—restricting how Chinese companies and other "prohibited foreign entities" may supply equipment, participate in ownership or funding, or otherwise benefit from material assistance. These new rules, effective in 2026, carry substantial penalties and will significantly affect how developers, investors, lenders, and tax equity providers approach project development and financing.
Join DWT partners Pamela Charles and Merrill Kramer, together with Jessie Robbins, SVP and Head of Project Finance at Pine Gate Renewables, and Karin Berry, Managing Director at NT Solar, for a Lexology webinar on how these requirements will reshape clean energy transactions. Drawing on deep experience in project finance, tax credit structures, and risk allocation, the panel discussed how stakeholders can prepare for evolving guidance and adapt deal strategies now.
Topics will include:
- Categories of prohibited foreign entities
- What constitutes "material assistance"
- Impacts on project finance, M&A, and joint ventures
- Managing compliance and risk exposure
- Anticipated Treasury and IRS guidance
This session was designed for in-house counsel, developers, investors, lenders, and law firm practitioners involved in clean energy transactions and compliance.
Speakers
- Pamela Charles, Partner & Chair of the Tax Practice, Davis Wright Tremaine
- Merrill Kramer, Partner, Energy Infrastructure & Projects, Davis Wright Tremaine
- Jessie Robbins, SVP & Head of Project Finance, Pine Gate Renewables
- Karin Berry, Managing Director, NT Solar