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IRS Issues Interim Guidance On "Material Assistance" From A Prohibited Foreign Entity
On February 12, 2026, the Department of the Treasury ("Treasury") and the Internal Revenue Service ("IRS") released Notice 2026-15 (the "Notice"), providing long-awaited interim guidance on the restrictions on receiving "material assistance" from a prohibited foreign entity ("PFE") that were enacted by the One Big Beautiful Bill Act (the "OBBBA").
Mayer Brown