The IRS recently released a set of Frequently Asked Questions (FAQs) for buyers of vehicles that might qualify for clean vehicle energy credits. These updates for for new, previously owned, and qualified commercial vehicles, and are contained in Fact Sheet 2024-26 (FS-2024-26), issued on July 26, 2024. These FAQs supercede earlier FAQs that were posted by the IRS.
These FAQ revisions include the following topics (these are the revised sections only):
Topic A: Eligibility rules for the New Clean Vehicle Credit: updated questions 2, 7, 8, 12 and 18, and added questions 15-17. •
Topic B: Income and Price Limitations for the New Clean Vehicle Credit: updated questions 3, 4, and 7-10, and added questions 12-14. •
Topic C: When the New Requirements Apply to the New Clean Vehicle Credit: updated questions 4 and 6. •
Topic D: Eligibility Rules for the Previously Owned Clean Vehicles Credit: updated questions 3 and 12 and added questions 13-15. •
Topic E: Income and Price Limitations for Previously Owned Clean Vehicles: updated question 2. •
Topic F: Claiming the Previously Owned Clean Vehicles Credit: updated question 3. •
Topic H: Transfer of New Clean Vehicle Credit and Previously Owned Clean Vehicle Credit: updated questions 1-3, 11, 12, 14-15 and 18, and added questions 23-30. •
Topic I: Registering a Dealer/Seller for Seller Reporting and Clean Vehicle Tax Credit Transfers: updated questions 4, 13, and 14, and added questions 19-30.
These FAQs are extensive and reasonably detailed, and the IRS notes that further modifications could be made. For that reason, we suggest that anyone who purchases a vehicle with the intent to claim an energy credit should go directly to the IRS website if there are any questions, as the IRS website will have the most recent guidance available. The immediate update is available at https://www.irs.gov/pub/taxpros/fs-2024-26.pdf (this can be copy and pasted to your browser).
While these FAQs are not defiinitive guidance and are subject to further change, the IRS notes that a taxpayer who reasonably and in good faith relies on these FAQs will not be subject to a penalty that provides a reasonable cause standard for relief, including a negligence penalty or other accuracy-related penalty, to the extent that reliance results in an underpayment of tax.
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