The "prohibited foreign entity" (PFE) test: A taxpayer is ineligible for credits if they are deemed a "prohibited foreign entity." This is defined as an entity that is both a "specified foreign entity" and a "foreign influenced entity." The "material assistance" restriction: This rule prohibits claiming credits if a project receives "material assistance" from a PFE. Investors are underwriting against these thresholds today by requiring supply chain transparency down to the "material assistance cost ratio." Material assistance: Policies can increasingly cover the factual accuracy of the material assistance calculations.