2023 Time-of-Sale Report Submission Deadline Extended

Last month, the IRS announced a second reporting deadline extension for auto dealerships that sold eligible electric and other clean energy vehicles (EVs) in 2023. The first extension was issued in January when there was a two-week extension to the filing deadline from January 15^th to January 31^st. This extension means dealers now have until February 15^th to submit the required time of sale reports for 2023 transactions. The additional time is needed to help sellers navigate compliance regulations including various filing options.  Complying with the new deadline is essential because a buyer can not claim the New Clean Vehicle Tax Credit without it. To help clients, prospects, and others, Wilson Lewis has provided a summary of the key details below.

What is a Time-of-Sale Report?

Dealers and sellers of vehicles eligible for the clean vehicle tax credit are required to submit time-of-sale reporting to the IRS so that everyone involved – dealers, sellers, and buyers – can claim the credit. The accuracy of these reports can help ensure the credit is applied properly without any speed bumps for either party.

Time-of-Sale Reporting Deadline Extension and Required Information

Originally, sellers and dealers had until January 15, 2024, to file 2023 time-of-sale reports, but that deadline has since been extended twice, now to February 15, 2024, for qualifying clean vehicle sales. The goal is to give sellers breathing room to comply with new reporting requirements.

Filing can be done either via secure email or by sending a fax with a cover sheet. The following information must be provided for eligible 2023 sales. including:

• Dealer/seller information including name, Employer Identification Number (EIN), and address for the principal place of business.
• Name of the buyer and taxpayer ID/Social Security number.,
• Maximum applicable credit amount.
• Vehicle details, including the sale date, price, VIN, and battery capacity.
• For new vehicles, a confirmation the buyer is the original user.
• Signed statement of accuracy which needs to include the following verbiage: “Under penalties of perjury, I declare that I have examined this report submitted to the IRS under 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.”

Emailing Time-of-Sale Reports

For email, sellers will need to send a password-protected Excel document, Form 15400, or a similar form to IRS.Clean.Vehicles.Seller.Reporting@IRS.gov, with a second email detailing the password to the file. Both emails should use the same subject line. Be sure not to include any full names, personally identifiable information, or Social Security numbers in a non-encrypted email unless the documents being submitted are password-protected.

Faxing Time-of-Sale Reports

When faxing information, dealers should send the information to 855-755-7437. The cover sheet should carry the subject: “2023 Clean Vehicle Time-of-Sale Report(s)” and should also have the dealer’s information, taxpayer information, the number of pages being faxed, and the date the fax is being sent. Again, be sure no sensitive information is included on the cover sheet, such as Social Security numbers.

Formats and Applicability of Reporting Rules

If the format has the necessary information that will be required on Form 15400, any format can be submitted. For sellers and dealers who may miss information, their applications will not be rejected. Instead, they will be contacted by someone who will manually review the 2023 seller reports to collect additional necessary information.

Contact Us

The extension is welcome news for many dealerships that have been struggling to properly file 2023 time of sale reports. Failure to comply will have a significant impact on customers expecting to receive the tax credit. If you have questions about the information outlined above or need assistance with a tax or accounting issue, Wilson Lewis can help. For additional information call 770-476-1004 or click here to contact us. We look forward to speaking with you soon.