Comment from American Public Power Association
American Public Power AssociationSupportTrade association
Summary: The American Public Power Association (APPA) is urging the Treasury and IRS to provide specific guidance on the new foreign-entity-of-concerns rules to ensure energy projects and nuclear tax credits are not unnecessarily blocked. They advocate for treating publicly offered debt as not issued to specified foreign entities and for applying the debt test prospectively to debt issued during the taxable year.
On behalf of the American Public Power Association, please find attached our comments in relation to Prohibited Foreign Entity Guidance as requested in IRS Notice 2026-15.