December 10, 2025, 2-3pm, ET
H.R.1 (OBBBA) imposed Prohibited Foreign Entities (PFE) rules that taxpayers must follow in claiming credits for their eligible energy projects. These rules, the next iteration of Foreign Entities of Concern rules, are challenging from a compliance perspective because they can be complicated and often unclear, which may lead to misunderstandings, stifled action, erroneous filings, or missed opportunities.
For Part 1 of the series, please join L4GG as we provide a refresher on the key components of PFE rules, including specified foreign entities, foreign controlled entities, foreign-influenced entities (including the so-called “payment” test), and material assistance. We will discuss how to test for these elements and highlight key aspects of the rules that lack clarity or impose a significant compliance burden. This webinar will also include an illustrative discussion of evaluating the compliance and regulatory risks associated with these rules for an Elective Pay entity. Register here.
*This program is pending MCLE accreditation in California.
SPEAKERS
Edward Yim, Director of Clean Energy: Climate Change & Environmental Justice
Edward has served in all levels of government as policy expert, thought leader, and legal counsel on clean energy and resilient infrastructure, and he has worked in the nonprofit and private sectors with energy companies and public utilities. As an energy policy advisor for the District of Columbia government, Edward led the development of its innovative climate action & energy plan, the citywide electrification roadmap, the first Solar for All program, and grid modernization strategies including non-wires and non-pipe alternatives. Recently, he helped implement the IRA Home Energy Rebates at the US Department of Energy, after serving as Director of State and Utility Policy at the American Council for an Energy Efficient Economy. At L4GG, he helps communities access IRA funding and navigate legal complexities of decarbonization planning.
He previously served in regulatory and governance roles across environmental nonprofits and state energy offices.
Camille Edwards-Bennehoff, Senior Staff Attorney: Clean Energy & Tax
Camille brings her passion for serving the public and wealth of experience as a tax attorney and tax preparer to Lawyers for Good Government (L4GG), where she advises on tax law matters. Before joining L4GG, Camille spent seven years working in the National Office of the Internal Revenue Service Office on Chief Counsel (IRS) where she worked on a variety of tax law guidance and litigation matters, including drafting guidance and providing advice for implementation of fuel tax credits under the Inflation Reduction Act of 2022 (IRA) and the Superfund excise taxes. Camille’s work on IRA matters included drafting notices for the section 40B (sustainable aviation fuel) and section 45Z (clean fuel production) credits. Before working for the IRS, Camille clerked for over two years for Special Trial Judge Peter Panuthos at the United States Tax Court where she wrote opinions and orders on a variety of tax cases including individual income taxes, tax penalty, and collection due process matters, and supervised a legal intern for the judicial chambers. She also worked on state and local tax matters and tax returns for PwC in San Diego and for a small tax law firm in San Diego.