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139 STAT. 268 PUBLIC LAW 119–21—JULY 4, 2025 respect to the determination under section 7701(a)(52) for any tax- able year, such deficiency may be assessed at any time within 6 years after the return for such year was filed.’’. (j) IMPOSITION OF ACCURACY-RELATED PENALTIES.— (1) IN GENERAL.—Section 6662 is amended by adding at the end the following new subsection: ‘‘(m) SUBSTANTIAL UNDERSTATEMENT OF INCOME TAX DUE TO DISALLOWANCE OF APPLICABLE ENERGY CREDITS.— ‘‘(1) IN GENERAL.—In the case of a taxpayer for which there is a disallowance of an applicable energy credit for any taxable year, for purposes of determining whether there is a substantial understatement of income tax for such taxable year, subsection (d)(1) shall be applied— ‘‘(A) in subparagraphs (A) and (B), by substituting ‘1 percent’ for ‘10 percent’ each place it appears, and ‘‘(B) without regard to subparagraph (C). ‘‘(2) DISALLOWANCE OF AN APPLICABLE ENERGY CREDIT.— For purposes of this subsection, the term ‘disallowance of an applicable energy credit’ means the disallowance of a credit under section 45X, 45Y, or 48E by reason of overstating the material assistance cost ratio (as determined under section 7701(a)(52)) with respect to any qualified facility, energy stor- age technology, or facility which produces eligible components.’’. (2) CONFORMING AMENDMENT.—Section 6417(d)(6) is amended by adding at the end the following new subparagraph: ‘‘(D) DISALLOWANCE OF AN APPLICABLE ENERGY CREDIT.—In the case of an applicable entity which made an election under subsection (a) with respect to an applicable credit for which there is a disallowance described in section 6662(m)(2), subparagraph (A) shall apply with respect to any excessive payment resulting from such dis- allowance.’’. (k) PENALTY FOR SUBSTANTIAL MISSTATEMENTS ON CERTIFI- CATION PROVIDED BY SUPPLIER.— (1) IN GENERAL.—Part I of subchapter B of chapter 68 is amended by inserting after section 6695A the following new section: ‘‘SEC. 6695B. PENALTY FOR SUBSTANTIAL MISSTATEMENTS ON CER- TIFICATION PROVIDED BY SUPPLIER. ‘‘(a) IMPOSITION OF PENALTY.—If— ‘‘(1) a person— ‘‘(A) provides a certification described in clause (iii)(II)(bb) of section 7701(a)(52)(D) with respect to any manufactured product, eligible component, or constituent element, material, or subcomponent of an eligible compo- nent, and ‘‘(B) knows, or reasonably should have known, that the certification would be used in connection with a deter- mination under such section, ‘‘(2) such person knows, or reasonably should have known, that such certification is inaccurate or false with respect to— ‘‘(A) whether such property was produced or manufac- tured by a prohibited foreign entity, or ‘‘(B) the total direct costs or total direct material costs of such property that was not produced or manufactured 26 USC 6695B. Definition.