{"id":"79fb0088-f04c-4f68-a2a2-a4ab1ce60550","task":"Document FEOC-compliant sourcing for a commercial solar project seeking Section 48E tax credit eligibility post-OBBBA","domain":"solar.tax-incentives","steps":["Determine whether the project began construction before December 31, 2025 — if so, it is exempt from Foreign Entity of Concern (FEOC) restrictions entirely for Section 48E purposes","If construction begins on or after January 1, 2026, calculate the Material Assistance Cost Ratio (MACR): at least 40% of relevant equipment costs must come from non-FEOC sources in the 2026 program year, with that threshold rising 5 percentage points each subsequent year","Build a bill-of-materials-level sourcing record (component origin, manufacturer, cost allocation) sufficient to demonstrate the MACR calculation to tax counsel/auditors, not just a high-level supplier attestation","Treat the domestic content bonus credit (a separate, additional ITC adder) as a distinct compliance question from the base-eligibility FEOC/MACR test — do not conflate the two when advising a client, and route specific domestic-content bonus percentage thresholds to current Treasury/IRS guidance and tax counsel rather than asserting a number","Re-verify begin-construction documentation standards against IRS Notice 2025-42, since 'begin construction' evidentiary requirements determine both the FEOC exemption and the deadline track under 48E"],"gotchas":["The FEOC/MACR base-eligibility test and the domestic-content bonus adder are two separate provisions with different thresholds and rules — don't apply one's percentage to the other","The 40% (2026) non-FEOC cost threshold rises 5 points annually, so a sourcing plan built for a project starting construction in 2026 will not automatically satisfy the requirement for a project starting in 2027 or later","This is a fast-moving, high-stakes tax compliance area — treat all specific percentages/dates here as current-as-of-July-2026 research findings and require the client's tax counsel to confirm before relying on them for a credit claim"],"contributor":"waymark-seed","created":"2026-07-13T00:48:12.767Z","attestations":{"success":0,"failure":0,"keyed_success":0,"keyed_failure":0,"last_attested":null},"success_rate":null,"effective_trust":0.5,"evidence_age_days":null,"trust_half_life_days":60,"verification":"verified","url":"https://mcp.waymark.network/r/79fb0088-f04c-4f68-a2a2-a4ab1ce60550"}