Dealer Delay The IRS announced that auto dealers have until January 31 to submit 2023 “Clean Vehicle Sales reports. This spreadsheet must have all the required data from all seller reports. Dealers may also submit copies of individual seller report Form 15400 or equivalent forms containing the required data the dealer used in calendar year 2023. The guidance from the IRS suggested dealers submit all of this via email. There is concern that this process will raise possible privacy and data security concerns because it involves the submission of documents containing sensitive customer data to a potentially unsecured IRS email address. The IRS is aware of this issue, and we are awaiting further guidance, which we expect shortly. Until then, we recommend dealers delay the submission of 2023 sales reports, which currently has a deadline of Jan. 31, 2024, until this issue can be resolved. Adding to the confusion, the process going forward is all online. The IRS Energy Credits Online (ECO) portal became operational on January 1, 2024. This portal is NOT for 2023 Year-End Reports, only for sales on or after January 1, 2024. Since the IRS is still calibrating the portal’s functionality, it is temporarily extending the 3-day time period to provide dealers and the IRS more time to submit and process seller reports. Dealers should continue to submit time-of-sale reports through the portal for all sales on and after January 1, 2024, and the IRS encourages dealers to use the extension only if they are unable to successfully submit a time-of-sale report when the vehicle is for a customer who intends to claim the tax credit on their tax return instead of transferring the credit.

Clear as mud? The IRS has announced online “office hours sessions” to answer questions and help dealers with time-of-sale reporting issues. To register, dealers must click on the “register here” link below for a specific help desk session. Click on the link below to sign up.