Corrected - 2023s purchased in 2022 will qualify for federal tax credit

[Scooby24]

Thread title is my interpretation. Don't yell at me if you don't agree, I'm just following the instructions.

Edit: to clarify - this isn't about assembly location, it's about the IRS qualifying 2023's purchased from 8/16 - 12/31 and it at least appears there's more going into that than just final assembly location, which has already been provided.

Per the IRS site for vehicles purchased in 2022 or before: https://www.irs.gov/credits-deductions/credits-for-new-electric-vehicles-purchased-in-2022-or-before

Qualified Vehicles
To qualify, a vehicle must:

• Have an external charging source
• Have a gross vehicle weight rating of less than 14,000 pounds
• Be made by a manufacturer that hasn't sold more than 200,000 EVs in the U.S.

You can find your vehicle's weight on the vehicle's window sticker.

Vehicles Purchased After August 16, 2022: New Final Assembly Requirement
If you buy a qualified electric vehicle between August 17, 2022 and December 31, 2022, the same rules apply, plus the vehicle must also undergo final assembly in North America.

To see if your model meets the assembly requirements, check the Department of Energy's page on Electric Vehicles with Final Assembly in North America. On that page you can:

• Confirm the assembly location for your specific vehicle using the VIN Decoder tool under "Specific Assembly Location Based on VIN."
• Check a list of qualifying Model Year 2022 and early Model Year 2023 electric vehicles under "For Vehicles Purchased before January 1, 2023."

Because some models are built in multiple locations, you should check both criteria for any specific vehicle.

So some 2023's will qualify. Go to the list of vehicles that qualify between 8/16 and 12/31 and the 2023 Mach-e does not qualify.

https://afdc.energy.gov/laws/electric-vehicles-for-tax-credit#/tab-2022

The recent 55k MSRP cap for 2023's applies to vehicles purchased AFTER Dec 31st 2022

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[phil]

"This list will be updated as vehicle manufacturers submit Fuel Economy labeling information and Part 583 vehicle identification information to the relevant government agencies."

 

[Scooby24]

"This list will be updated as vehicle manufacturers submit Fuel Economy labeling information and Part 583 vehicle identification information to the relevant government agencies."

It does appear that this hasn't been submitted yet so I'd consider that potential hope for '23 owners.

https://www.nhtsa.gov/sites/nhtsa.gov/files/2022-12/MY2023-AALA-Alphabetical-11-30-22_1.pdf

edit: Man...I don't know. Rivian is on the '23 exception list, but they aren't on the 583 spreadsheet at all.

This is definitely concerning at the very least.

 

[gryphon]

The premise of this thread is wrong:

Right from the DOE’s page. Please stop, you’re unnecessarily worrying people.

 

[Scooby24]

The premise of this thread is wrong:

Right from the DOE’s page. Please stop, you’re unnecessarily worrying people.

You've not read my post. It's nothing to do with the Assembly location. It has to do with the Timing, and the wording of the 2023 model years purchased in 2022 needing to be qualified and right now it's not.

Edit: the bolding on the assembly location was pulled from the IRS's site. I remove the formatting to clarify.

 

[phil]

It does appear that this hasn't been submitted yet so I'd consider that potential hope for '23 owners.

https://www.nhtsa.gov/sites/nhtsa.gov/files/2022-12/MY2023-AALA-Alphabetical-11-30-22_1.pdf

edit: Man...I don't know. Rivian is on the '23 exception list, but they aren't on the 583 spreadsheet at all.

This is definitely concerning at the very least.

I have to think the '23 Mustangs will be ok, since we know they are still manufactured in Mexico. I can't think of any reason why they should be treated any different from the '22s. But for sure the government is making this whole thing a lot more "exciting" than it needs to be...

 

[Scooby24]

I have to think the '23 Mustangs will be ok, since we know they are still manufactured in Mexico. I can't think of any reason why they should be treated any different from the '22s. But for sure the government is making this whole thing a lot more "exciting" than it needs to be...

Well they are calling for 583 requirements to be able to dictate if they qualify so it seems they are looking at the 2023s separate from 2022s on material percentages in the same way they were assembly location.

So ford's submitted EPA and Assembly location but not the material percentages. They've said they think they'll qualify....but if they don't qualify for the full 7500 I would bet the IRS excludes them entirely.

 

[Logal727]

What a mess

 

[Scooby24]

More reason for skepticism.

The E-Transit qualifies but the MME doesn't. The current posted 583 has the same details available for both. I can only conclude there's either a massive disconnect between their updates or the same info has been submitted and the e-transit made the cut and the MME didn't.

 

[gryphon]

You've not read my post. It's nothing to do with the Assembly location. It has to do with the Timing, and the wording of the 2023 model years purchased in 2022 needing to be qualified and right now it's not.

Edit: the bolding on the assembly location was pulled from the IRS's site. I remove the formatting to clarify.

I’ve read your post, it’s wrong.

You've modified the formatting of the IRS guidance, but it is still accurate and the bolding on the assembly location is still there. Here you go if you don't believe me:

https://www.irs.gov/credits-deductions/credits-for-new-electric-vehicles-purchased-in-2022-or-before

Now run a valid VIN from any 2023 Mach E like I did and see that it meets the requirements. Nothing in those criteria invalidates a 2023 Mach E purchased and delivered before 1/1/23.

 

[Scooby24]

I’ve read your post, it’s wrong.

You've modified the formatting of the IRS guidance, but it is still accurate and the bolding on the assembly location is still there. Here you go if you don't believe me:

https://www.irs.gov/credits-deductions/credits-for-new-electric-vehicles-purchased-in-2022-or-before

Now run a valid VIN from any 2023 Mach E like I did and see that it meets the requirements. Nothing in those criteria invalidates a 2023 Mach E purchased and delivered before 1/1/23.

I beg your pardon but if you're going to say I'm wrong, please read the full wording of the IRS's guidance which states clearly:

To see if your model meets the assembly requirements, check the Department of Energy's page on Electric Vehicles with Final Assembly in North America. On that page you can:

• Confirm the assembly location for your specific vehicle using the VIN Decoder tool under "Specific Assembly Location Based on VIN."
• Check a list of qualifying Model Year 2022 and early Model Year 2023 electric vehicles under "For Vehicles Purchased before January 1, 2023."

Because some models are built in multiple locations, you should check both criteria for any specific vehicle.

You may feel it's wrong, but it's not. (edit: I was wrong!)

It states both criteria need to be checked. Confirming assembly location AND that it's on the list.

It's suggesting that final build location would be the reason it might not be qualified on the list, but the fact is, they have the final assembly location submitted, and it's not on the list.

But the E-Transit is...

 

[gryphon]

I beg your pardon but if you're going to say I'm wrong, please read the full wording of the IRS's guidance which states clearly:



You may feel it's wrong, but it's not.

It states both criteria need to be checked. Confirming assembly location AND that it's on the list.

It's suggesting that final build location would be the reason it might not be qualified on the list, but the fact is, they have the final assembly location submitted, and it's not on the list.

But the E-Transit is...

Oh, I've read it and I'll wager my tax law degree on the fact that nowhere in the language used by the IRS does it say that you must see that a vehicle qualifies under both methods of verification. The VIN tool will always be more specific and detailed than a list. This is why it suggests you use both methods, but it does not mandate both methods. You may have overlooked their use of the word "should," which does not mean the same as you "must."

If you run a valid '23 MME VIN, as I did in Post #4, you will see that it qualifies under the Final Assembly requirement.

 

[phil]

Oh, I've read it and I'll wager my tax law degree on the fact that nowhere in the language used by the IRS does it say that you must see that a vehicle qualifies under both methods of verification. The VIN tool will always be more specific and detailed than a list. This is why it suggests you use both methods, but it does not mandate both methods. You may have overlooked their use of the word "should," which does not mean the same as you "must."

If you run a valid '23 MME VIN, as I did in Post #4, you will see that it qualifies under the Final Assembly requirement.

If all '23 MME VINs are qualified, then what do you think is the reason that the '23 model does not yet appear on the qualified model list?

Simple oversight/error? Just delayed, and it will appear soon? Some 2023 VINs are qualified, but some are not?

 

[Scooby24]

Oh, I've read it and I'll wager my tax law degree on the fact that nowhere in the language used by the IRS does it say that you must see that a vehicle qualifies under both methods of verification. The VIN tool will always be more specific and detailed than a list. This is why it suggests you use both methods, but it does not mandate both methods. You may have overlooked their use of the word "should," which does not mean the same as you "must."

If you run a valid '23 MME VIN, as I did in Post #4, you will see that it qualifies under the Final Assembly requirement.

After hearing your explanation, I may indeed be wrong and would be happy to eat crow.

But why would they put little stipulations like this? Why are there further conditions for eligibility based on purchase date? What are those further stipulations? What purchase date are they referencing? January 1st? If so why are they calling that out here on this table which is only populated under the 8-17 to 12-31 list?

 

[Scooby24]

So all this is IRS guidance of the law. Let's look at the law.

``Sec. 30D. Clean vehicle credit.''.

(j) <>
Gross-up of Direct Spending.--Beginning in fiscal year 2023 and each
fiscal year thereafter, the portion of any credit allowed to an eligible
entity (as defined in section 30D(g)(2) of the Internal Revenue Code of
1986) pursuant to an election made under section 30D(g) of the Internal
Revenue Code of 1986 that is direct spending shall be increased by
6.0445 percent.

(k) <> Effective Dates.--
(1) In general.--Except as provided in paragraphs (2), (3),
(4), and (5), the amendments made by this section shall apply to
vehicles placed in service after December 31, 2022.

K So paragraphs 2, 3, 4 and 5 are applicable BEFORE 12/31/2022.

(2) Final assembly.--The amendments made by subsection (b)
shall apply to vehicles sold after the date of enactment of this
Act.
(3) Per vehicle dollar limitation and related
requirements.--The amendments made by subsections (a) and (e)
shall apply to vehicles placed in service after the date on
which the proposed guidance described in paragraph (3)(B) of
section 30D(e) of the Internal Revenue Code of 1986 (as added by
subsection (e)) is issued by the Secretary of the Treasury (or
the Secretary's delegate).

[[Page 136 STAT. 1962]]

(4) Transfer of credit.--The amendments made by subsection
(g) shall apply to vehicles placed in service after December 31,
2023.
(5) Elimination of manufacturer limitation.--The amendment
made by subsection (d) shall apply to vehicles sold after
December 31, 2022.

So 2 is effective as signed.

4 and 5 state the amendments go in after 12/31.

But 3. What the hell is 3 saying?

In service after date on which proposed guidance described in 3b?

I'm trying to follow that. That's when the critical mineral and MSRP go into effect. Seems there's more to that than just a 12/31 date.

Am I to interpret that could be up in the air based on what the Secretary of Treasury issues?

So it could still be more than just final assembly?

edit: OK so found 3(B) of 30D(e)

(B) Deadline for proposed guidance. Not later than December 31, 2022, the Secretary shall issue proposed guidance with respect to the requirements under this subsection.

So was this guidance provided?

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