Denial of clean energy tax benefits to companies connected to countries of concern

(a) In general Chapter 77 of the Internal Revenue Code of 1986 is amended by adding at the end the following new section: 7531. Denial of clean energy tax benefits to companies connected to countries of concern (a) In general In the case of any taxpayer that is a disqualified company, this title shall be applied without regard to sections 30C, 40, 40A, 40B, 45, 45Q, 45U, 45V, 45W, 45X, 45Y, 45Z, 48, 48C, 48E, 179D, 6426(c), 6426(d), 6426(e), and 6427(e). (b) Disqualified company For purposes of this section— (1) In general The term disqualified company means any entity— (A) created or organized under the laws of, or controlled by, one or more governments of a foreign country that is a country of concern, or (B) controlled (in the aggregate) by one or more entities described in subparagraph (A). (2) Country of concern The term country of concern means the People’s Republic of China, the Russian Federation, the Islamic Republic of Iran, or the Democratic People’s Republic of Korea. (3) Control The term control has the meaning given such term under section 954(d)(3), determined by treating the rules of section 958(a)(2) as applying to both foreign and domestic corporations, partnerships, trusts, and estates. (4) Government of a foreign country The term government of a foreign country means a national government of a foreign country, an agency or government instrumentality of a national government of a foreign country, a dominant or ruling political party of a foreign country, or any individual currently in a senior role of a country of concern and with substantial authority over policy, operations, or the use of government-owned resources of the foreign country.. (b) Clerical amendment The table of sections for chapter 77 of such Code is amended by adding at the end the following new item: Sec. 7531. Denial of clean energy tax benefits to companies connected to countries of concern.. (c) Guidance Not later than 180 days after the date of the enactment of this Act, the Secretary of the Treasury (or the Secretary’s delegate) shall issue guidance regarding implementation of this section. (d) Effective date The amendments made by this section shall apply to taxable years beginning on or after the date that is 180 days after the date on which the Secretary publishes guidance under subsection (c).