Final regulations confirming that entities wholly owned by tribal governments share the tax status of their owning tribes — not subject to federal income tax, and eligible for elective-pay clean energy credits. Applies to taxable periods beginning on or after Jan 1, 2026, with optional retroactive application (refunds via Form 1120-X). Treasury committed to separate consultation with tribes and TTAC before issuing guidance on PARTIALLY tribally owned entities — watch for that window to open.
Effective: Jan 1, 2026