On December 20, 2023 and again on December 29, the IRS released updated versions of frequently asked questions (FAQs) specific to the dealer registration and time of sale reporting process related to the sale of clean vehicles potentially eligible for an energy credit. Contained in the latest versions are more than 30 new FAQs focused on such topics as helping dealers determine how to register when multiple dealerships are part of the same federal income tax return, what a dealer/seller will need to do in connection with 2023 time of sale reports, who the primary user(s) should be for the IRS Energy Credit Online portal, and additional FAQs intended to call attention to the guidance issued previously based upon taxpayer feedback.
ACTION ITEM: As noted in Q17 (listed below), sellers must file Form 15400 Time of Sale reports by January 15, 2024 for all 2023 sales. Even given the short timeframe, the IRS has indicated more information is forthcoming, as the currently available Energy Credits Online portal should not be used for sales prior to January 15, 2024.
FAQs of note include:
- Q12. Many dealers have multiple locations. Does each location need to register? How do I know which of my entities should register? (updated December 20, 2023)
- Q15. Our account is under “manual review,” saying that our bank account information could not be validated. Should we be concerned at this time? (added December 20, 2023)
- Q17. The deadline to submit time of sale reports generated in 2023 is 1/15/2024. How are the time of sale reports generated in 2023 submitted to the IRS, via mail or via IRS Energy Credits Online (ECO)? (added December 20, 2023)
- Q20. Will the IRS be providing the standard disclosure forms and attestations from the buyer that dealers are required to provide buyers? (added December 20, 2023)
- Q23. What is the definition of a vehicle report? Is that the same as an internal government report or commercial source (i.e., CarFax)? (added December 20, 2023)
- Q24. I registered my dealership today and the site was our corporate IRS login. I am the CFO. Our sales managers will be submitting the documentation online. Will they segment the login away from the general corporate tax account? I ask because dealers may not want their managers to have full access to their IRS corporate site. (added December 20, 2023)
- Q25. Is the dealer required to give their EIN only to the IRS or to the buyer as well? (added December 20, 2023)
- Q38. We have multiple franchises under one EIN, will we have to input all dealerships under that EIN? (added December 20, 2023)
- Q40. Are there any concerns with having the personal ID.me account effectively linked to the business’ clean energy account, such as if the employee were to leave the company? (added December 20, 2023)
- Q47. How can additional users get access to the entity’s IRS Energy Online account? (added December 29, 2023)
The IRS also released the following publications to help dealerships with the registration and time of sale reporting process, transfers of clean vehicle tax credits, and management of additional users and their permissions within the IRS Energy Credit Online portal:
- Publication 5867 – Clean Vehicle Dealer and Seller Energy Credits Online Registration User Guide
- Publication 5867-A – Inflation Reduction Act (IRA) New and Used Clean Vehicle Time-of-Sale Reporting User Guide
- Publication 5899 – Clean Vehicle Credit Transfer: Information you need to provide to the registered dealer
- Publication 5900 – Important Information for Consumers Transferring Clean Vehicle Tax Credits
- Publication 5902 – Clean Energy Authorization Permission Management
Lastly, the IRS released a video to help dealers/sellers learn how to submit time of sale reports and download or void reports that were previously submitted.
Dealers/sellers with questions specific to the registration or time of sale reporting process can email the IRS at irs.clean.vehicles.dealer.info@irs.gov.
How FORVIS Can Help
Dealers/sellers who need to register with the IRS Energy Credit Online portal or submit a time of sale report may have questions concerning the process. If you have questions or need assistance, please reach out to a professional at FORVIS.