NADA Recommends Dealers Delay Submitting 2023 Clean Vehicle Sales Reports
Recently, NADA sent an all-member email (see below) informing dealers of IRS guidance regarding the submission of 2023 clean vehicle sales reports. The process outlined by the IRS appears to 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.
IRS Provides Guidance for 2023 Annual Clean Vehicle Sales Report (Original Email)
What’s new: The IRS today provided much-anticipated guidance for dealers regarding submission of their 2023 qualifying clean vehicle sales reports and extended the deadline for the reports to Jan. 31, 2024.
Why it matters: Sellers must file reports within fifteen days after the end of the calendar year regarding their clean vehicle sales in order for a vehicle to be eligible for the clean vehicle credit under § 30D or § 25E (pursuant to Rev. Proc. 2022-42). These reports, therefore, were originally due on Jan. 15, 2024; because the IRS has extended the deadline, dealers now must submit their reports to the IRS by Jan. 31, 2024.
More guidance: The IRS also provided guidance regarding the manner and method by which dealers are to submit their reports. Specifically, the reports are to be submitted by e-mail to the following e-mail address: IRS.Clean.Vehicles.Seller.Reporting@IRS.gov.
In addition, the IRS specified that it prefers the reports be provided in an Excel spreadsheet containing all the required data from all seller reports a dealer prepared in calendar year 2023. 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. Dealers that used reasonable alternatives to Form 15400 in providing the required seller reports to buyers do not need to prepare the information in the Form 15400 format.
