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139 STAT. 271 PUBLIC LAW 119–21—JULY 4, 2025 31, 2025, if the construction of such property includes any material assistance from a prohibited foreign entity (as defined in section 7701(a)(52)).’’. (2) ADDITIONAL RESTRICTIONS.—Section 48E(d) is amended by adding at the end the following new paragraph: ‘‘(6) RESTRICTIONS RELATING TO PROHIBITED FOREIGN ENTI- TIES.— ‘‘(A) IN GENERAL.—No credit shall be determined under subsection (a) for any taxable year if the taxpayer is— ‘‘(i) a specified foreign entity (as defined in section 7701(a)(51)(B)), or ‘‘(ii) a foreign-influenced entity (as defined in sec- tion 7701(a)(51)(D), without regard to clause (i)(II) thereof). ‘‘(B) EFFECTIVE CONTROL.—In the case of a taxpayer for which section 7701(a)(51)(D)(i)(II) is determined to apply for any taxable year, no credit shall be determined under subsection (a) for such taxable year if such deter- mination relates to a qualified facility described in sub- section (b)(3) or energy storage technology described in subsection (c)(2).’’. (3) RECAPTURE.— (A) IN GENERAL.—Section 50(a) is amended— (i) by redesignating paragraphs (4) through (6) as paragraphs (5) through (7), respectively, (ii) by inserting after paragraph (3) the following new paragraph: ‘‘(4) PAYMENTS TO PROHIBITED FOREIGN ENTITIES.— ‘‘(A) IN GENERAL.—If there is an applicable payment made by a specified taxpayer before the close of the 10- year period beginning on the date such taxpayer placed in service investment credit property which is eligible for the clean electricity investment credit under section 48E(a), then the tax under this chapter for the taxable year in which such applicable payment occurs shall be increased by 100 percent of the aggregate decrease in the credits allowed under section 38 for all prior taxable years which would have resulted solely from reducing to zero any credit determined under section 46 which is attributable to the clean electricity investment credit under section 48E(a) with respect to such property. ‘‘(B) APPLICABLE PAYMENT.—For purposes of this para- graph, the term ‘applicable payment’ means, with respect to any taxable year, a payment or payments described in section 7701(a)(51)(D)(i)(II). ‘‘(C) SPECIFIED TAXPAYER.—For purposes of this para- graph, the term ‘specified taxpayer’ means any taxpayer who has been allowed a credit under section 48E(a) for any taxable year beginning after the date which is 2 years after the date of enactment of this paragraph.’’, (iii) in paragraph (5), as redesignated by clause (i), by striking ‘‘or any applicable transaction to which paragraph (3)(A) applies,’’ and inserting ‘‘any applicable transaction to which paragraph (3)(A) applies, or any applicable payment to which paragraph (4)(A) applies,’’, and Time period. Definitions. Determination. Applicability.