Back in the beginning of November, the IRS released guidance on how to report the time-of-sale of the electric vehicles (“EVs”). We explained the registration in a prior Our Thoughts On article, which can be found here.
Most dealers appear to dread this program and registration because of their lasting memories of how the Cash for Clunker program went for them. Just like with most things, the IRS delayed guidance, which put a sense of urgency on taxpayers and caused frustration. Our year-end discussions with our dealer clients seemed to be dominated by the EV seller’s reports and on-line IRS portal.
The rule for the time-of-sale reports is within three days of the sale. The online registration has been delayed by various things such as: the IRS delay of the guidance; the dealers’ dreading it; the backlog of registrations; the verification of dealer licenses and bank account confirmation. These are among the few snags in the process. The IRS has acknowledged it and has provided more time.
The IRS released Rev. Procedure 2023-38 which extends the three-day time period through January 16. This means that the time-of-sale transactions for EV deals from January 1, 2024 to January 16, 2024 can be submitted by January 19, 2024. Please note that the vehicles that qualify for the Commercial Clean Vehicle Credit (45W) do not need to be submitted, which includes leased vehicles.
If you still need assistance regarding your online registration of EV reporting, please reach out to Steve Barber or Brett Cubellis from our SD Auto Advisor group.
About Schneider Downs Automotive Industry Group
The Schneider Downs Automotive industry group serves dealers of all sizes, from single-point locations to mega-dealerships. Our members cross departments and meet regularly to ensure efficiencies in the services provided to our clients and discuss issues, regulations and trends affecting the automotive industry.
To discuss, please reach out to Steve Barber or any of the other SD Auto Advisors. To learn more, visit our Automotive Industry Group page.
