Understanding New Restrictions on Foreign Entities and Tax Credit Deals
Navigating the Landscape of FEOC Restrictions
Introduction to the new regulations impacting foreign entities.
What are Foreign Entities of Concern (FEOCs)?
Defining FEOCs and their implications.
The Impact of the OBBBA on Business Operations
How the legislation reshapes the business environment.
Structuring Tax Credit Monetization Post-OBBBA
Exploring innovative approaches to tax credit transactions.
Key Considerations for Monetization Strategies
Factors to evaluate when structuring deals.
Common Transaction Models and Their Adaptations
Analyzing established methods and necessary adjustments.
- Direct Purchase Agreements
- Tax Equity Investments
- Lease Pass-Through Structures
Practical Guidance for Businesses
Actionable advice for compliance and strategic planning.
Due Diligence and Compliance Checks
Ensuring adherence to new rules.
Engaging Legal and Financial Advisors
The importance of expert consultation.
- Assess your entity’s FEOC status.
- Review existing and proposed transactions.
- Consult with specialized legal counsel.
- Explore alternative financing and monetization structures.
Conclusion and Next Steps
Summarizing key takeaways and encouraging proactive measures.