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Second Extension Provided for 2023 Time-of-Sale Reporting

By February 15, dealers and sellers must file 2023 time-of-sale reports to the IRS for qualifying clean vehicle sales via one of two methods. Read on for more.
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UPDATED Action Item: The IRS announced a new extension date for filing time-of-sale reports. Sellers now have until February 15, 2024 (the previous cutoff was January 31, 2024) to file 2023 time-of-sale reports using one of the two following options: 1) Emailing a password protected Excel document or Form 15400 (or something similar) to Immediately afterwards, send a follow-up email with the same subject line to the same email address with the password to the file; or, 2) Fax the required information to 855-755-7437.

On January 9, 2024, the IRS announced the first extension to the due date that sellers must provide time-of-sale reports to the IRS for 2023 qualifying clean vehicle sales. Previously, sellers had until January 15, 2024 to submit these reports, but pursuant to the first extension sellers would have had until January 31, 2024. On January 30, 2024, the IRS announced a second extension indicating that 2023 time-of-sale reports are now due by February 15, 2024. The IRS has currently provided sellers with two methods to summit their 2023 time-of-sale reports.

Sending via email

The IRS indicated that copies of 2023 time-of-sale reports that were previously provided to eligible buyers should be submitted to Preferably, the IRS would receive an Excel spreadsheet with all the required information from a seller for all qualifying sales during 2023. However, a seller may submit copies of Form 15400 or similar forms that include all the required information. Sellers that previously utilized a form similar to Form 15400 in connection with 2023 qualified sales do not need to now prepare a Form 15400 for such sales. It is worth noting that this guidance specific to what may need to be filed with the IRS is different than previously provided by the IRS as discussed in this recent FORsight.

On January 12, 2024, the IRS issued further guidance in connection with utilizing email to send taxpayer sensitive information. Under the “Sending us email” section the IRS indicates that sellers should take the following steps:

  • Verify the email address they are sending it to is:
  • Standard email is not encrypted. Thus, certain information should not be included in the subject line or body of the email including full names, Social Security or taxpayer identification numbers, personal addresses, or phone numbers.
  • Encrypt and password protect any file that will be sent to the IRS. Choose a strong password that is at least 12 characters long with a mix of letters, numbers, and symbols
  • The IRS will accept any common file format including Microsoft Word, Excel, Adobe Acrobat (PDF), or images such as JPG and TIFF
  • As soon as the encrypted file is sent to the IRS, send a follow-up email that includes the password with the same subject line of the email just sent

The IRS provides a link to the U.S. Department of Treasury’s guide to encrypting and password protecting Microsoft Office and Adobe Acrobat (pdf) documents.

Sending via fax

New: On January 25, 2024, the IRS provided sellers with a second option of e-fax to file 2023 time-of-sale reports. If faxing, sellers should include a cover sheet with the following information:

  • Subject: 2023 Clean Vehicle Time-of-Sale Report(s)
  • The following sender’s information: Name, title, phone number, and address
  • Name of the taxpayer
  • Date
  • Number of pages to be faxed including the cover sheet

Sellers should not include any sensitive information such as their employer identification number or Social Security number on the cover sheet.

As a reminder, the following information regardless of which method used is required to be provided to qualified buyers and the IRS in connection with a qualified sale in 2023:

  • Seller/dealer name and taxpayer ID number (see FAQ 25 for guidance)
  • Buyer’s name and taxpayer ID number
  • Maximum credit under IRC 30D for new clean vehicles or IRC 25E for previously owned clean vehicles
  • VIN, unless one was not assigned to the vehicle
  • Battery capacity
  • Date of sale
  • Sale price
  • On new clean vehicles, confirmation that the buyer is the original user

Each report must also include a statement signed by a representative of the seller/dealer that must read: “Under penalties of perjury, I declare that I have examined this report submitted to the IRS pursuant to Revenue Procedure 2022-42 by [insert name of Seller], and to the best of my knowledge and belief I certify that this report is true, correct, and complete.”

The extensions to file 2023 time-of-sale reports are in addition to the one previously announced by the IRS in connection with 2024 time-of-sale reports that must be submitted through the IRS Energy Credit Online (IRS ECO) portal beginning January 1, 2024. This announcement by the IRS provides temporary relief to the three-day submittal requirement after a qualified sale of a time-of-sale report through the IRS ECO beginning January 1, 2024.  For any time-of-sale report due between January 1, 2024 and January 16, 2024, sellers/dealers now have until January 19, 2024, to submit the report.

For additional information pertaining to the 2023 time-of-sale reporting, see FAQs 13, 17, 18, and 19 here.

For more details see Rev. Proc. 2022-42 and Rev. Proc. 2023-33.

How Forvis Mazars 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 need assistance, please reach out to a professional at Forvis Mazars.

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