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.

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About our guest

Jennifer Bernardini is a managing director in our Specialized Tax Services Washington National Tax Services Federal Tax Services practice with a primary focus on energy resilience and sustainability taxation matters. Jennifer has over 20 years of experience in energy tax law and policy. Prior to joining PwC, Jennifer served for over 20 years in the US Treasury Department. Jennifer's practice focuses on tax issues related to renewable energy, regulated utilities, natural resources, and manufacturing. In recent years, Jennifer was heavily involved in the drafting of Inflation Reduction Act (IRA) credit guidance and provided technical assistance to the drafters of the One Big Beautiful Bill Act (OB3).

About our guest host

Diana Stoltzfus is a sustainability partner in the Professional Practice Group within the National Office. Diana helps to shape our firm’s perspective on regulatory matters, responses to rulemakings, and policy development and implementation related to significant new rules and regulations. Diana was previously the Deputy Chief Accountant in the Office of the Chief Accountant (OCA) of the Professional Practice Group in the OCA at the SEC. She focused on providing guidance related to auditing, independence, and internal controls.

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Sustainability now: Energy tax credits and the FEOC rule