Post #72 shows the EXACT IRS WORDING.Can you clarify where and who exactly has interpreted the IRS reg to mean the day the car is registered? I had heard this interpretation from a dealership, but didn’t know if they were correct or where exactly they got this information? I ask because in the Turbo Tax Forums some of those folks are saying that Date Placed In Service means the date you take legal ownership which is the day you signed a legal contract and not when you first took physical possession of the vehicle from the dealership…and they never mentioned this concept of the DMV Vehicle Registration Date that the dealer completes and sends to the DMV on the customer’s behalf as the Date Placed In Service. Thank you for any information you can provide.
Thank you for the reply and information…I apologize for asking for more clarification. If you don’t mind, please allow me to provide a more specific scenario to confirm my understanding. If I sign a contract to purchase a vehicle (via loan and not cash) during the last week of December, 2022 (next week) for an EV that has met the 200k cap (Tesla or GM), but I don’t take physical possession of the vehicle until January 1, 2023, do you believe I would qualify for the tax credit since the 200k cap disappears on January 1, 2023 (and both autos have final assembly in NA and as of Monday 12/19/2022 the battery sourcing requirement details are delayed until March)? Or is your point on the IRS regulations, is that the only date that matters for claiming the tax credit is the date put on the title by the dealer…regardless of when I would take physical possession of the vehicle? But is it correct you are also saying that typically the date on the title is set to the date the customer takes physical possession of the vehicle…since before the customer takes physical possession the dealer still owns the car and therefore would not switch the title to the customer’s name? And if so, is that because the date on the title represents the change or establishment of legal ownership…which is what actually determines the date that should be entered in the “Date Placed in Service” field in line 3 of the IRS Form 8936 when submitting your taxes and claiming the EV tax credit? Or did I miss the point again? 😞 And is it correct, you are saying that the date on the initial DMV registration form that the dealer fills out for the customer and submits to the DMV doesn’t matter at all? And last item, are you saying Post # 72 contains the language from the IRS Regulations regarding the date on title being the specific date that determines EV tax credit eligibility? I was trying to find where that language is that shows this interpretation of the IRS Regulation on EV tax credit eligibility being determined by the date on the title, but I didn’t see it on Post #72…although I may have missed it. Thanks again for your help…all this information has gotten me quite confused so I am hoping you or others much more educated and experienced with this stuff can help me properly interpret the eligibility to claim the EV tax credit.Post #72 shows the EXACT IRS WORDING. You haven't signed a legal contract when you place your order. And the IRS regulations are quite clear that title must pass per your state's rules, which has nothing to do with registration by the state since that takes time. Title doesn't pass until you take possession. If you don't take delivery by this coming Saturday, December 31st, it's in 2023.
That could work. Sounds legit to me.If I sign a contract to purchase a vehicle (via loan and not cash) during the last week of December, 2022 (next week) for an EV that has met the 200k cap (Tesla or GM), but I don’t take physical possession of the vehicle until January 1, 2023, do you believe I would qualify for the tax credit since the 200k cap disappears on January 1, 2023 (and both autos have final assembly in NA and as of Monday 12/19/2022 the battery sourcing requirement details are delayed until March)?
Why are you asking on a Mach-E forum about Tesla or GM cars?Thank you for the reply and information…I apologize for asking for more clarification. If you don’t mind, please allow me to provide a more specific scenario to confirm my understanding. If I sign a contract to purchase a vehicle (via loan and not cash) during the last week of December, 2022 (next week) for an EV that has met the 200k cap (Tesla or GM), but I don’t take physical possession of the vehicle until January 1, 2023, do you believe I would qualify for the tax credit since the 200k cap disappears on January 1, 2023 (and both autos have final assembly in NA and as of Monday 12/19/2022 the battery sourcing requirement details are delayed until March)? Or is your point on the IRS regulations, is that the only date that matters for claiming the tax credit is the date put on the title by the dealer…regardless of when I would take physical possession of the vehicle? But is it correct you are also saying that typically the date on the title is set to the date the customer takes physical possession of the vehicle…since before the customer takes physical possession the dealer still owns the car and therefore would not switch the title to the customer’s name? And if so, is that because the date on the title represents the change or establishment of legal ownership…which is what actually determines the date that should be entered in the “Date Placed in Service” field in line 3 of the IRS Form 8936 when submitting your taxes and claiming the EV tax credit? Or did I miss the point again? 😞 And is it correct, you are saying that the date on the initial DMV registration form that the dealer fills out for the customer and submits to the DMV doesn’t matter at all? And last item, are you saying Post # 72 contains the language from the IRS Regulations regarding the date on title being the specific date that determines EV tax credit eligibility? I was trying to find where that language is that shows this interpretation of the IRS Regulation on EV tax credit eligibility being determined by the date on the title, but I didn’t see it on Post #72…although I may have missed it. Thanks again for your help…all this information has gotten me quite confused so I am hoping you or others much more educated and experienced with this stuff can help me properly interpret the eligibility to claim the EV tax credit.
Man… I must be slow or something…what I see on 8936 for Line 7 is:What's so hard. Just go to the irs regulations, form 8936 and the links on the form explanation, not what some dealer said or what some forum member or turbotax said. You own the car the date of title transfer no matter if the car sits at the dealer or in your garage. If you try fudging the date on the title transfer application I'm pretty sure that would be illegal.
In the links you will find:
.07 Acquired. A vehicle is not “acquired” before the date on which title to that vehicle passes under state law.
Okay, sorry to be dumb here, but I understand the date on the title is entered by the dealer, is that correct? So it is the date on the title the dealer submits to the DMV that eventually you get a copy of that is the date you are describing is 5/31 for you, is that correct?Why are you asking on a Mach-E forum about Tesla or GM cars?
Sounds like you want to do the sale this week but take possession next week for a vehicle that doesn't qualify until 1/1/23. Given that you're signing the paperwork, leaving the car at the dealer is irrelevant - it's yours. Title passed at the dealer this week and you get no rebate for a 2023 purchase.
The date on the title would be what the state says it is. I bought my 2022 Mach-E on May 5/17. The state dated my title 5/31. Irrelevant - title passed to me on May 17th when I took possession. The date on a title is irrelevant. The date you take POSSESSION is relevant.
Last try.Okay, sorry to be dumb here, but I understand the date on the title is entered by the dealer, is that correct? So it is the date on the title the dealer submits to the DMV that eventually you get a copy of that is the date you are describing is 5/31 for you, is that correct?
I was reading all this stuff about Tesla customers waiting to take physical delivery of their cars until January 1 to qualify for the tax credit and therefore, why Tesla offered the $7500 upfront last Wednesday to customers who take delivery by 12/31/2022…so I was assuming the physical possession mattered…but maybe your point is that when they take possession on January 1, Tesla will put a January 1 date on the title to submit to the DMV, is that correct?
Okay, thank you…the title application date put in by the dealer does make a lot of sense since the date on the final title can be much later as it takes time for the state to process the application and it would be variable. So I guess I will put the application date of the title entered by the dealer in line 3, “Date Placed in Service” field of the IRS Form 8936! That seems correct and honest. 🙂Date on title application is put on by dealer. Date title is issued is put on by state. I believe the date on the title application is the important date. Form 8936 has a Part II for business and Part III for personal use. IRS uses both the terms date acquired and put in service and I agree that can be confusing. The sentence I linked earlier about acquired was found under definition of terms. I doubt irs is going to check if you put your first mile on the car Dec 31 or Jan 1 as long as it is titled to you in 2022. Don't let this screw up your Christmas. 😀
And that date should be the same date you showed up, signed the paperwork, and took home the car - or left it at the dealer for some reason. The dealer can't make up a date.Okay, thank you…the title application date put in by the dealer does make a lot of sense since the date on the final title can be much later as it takes time for the state to process the application and it would be variable. So I guess I will put the application date of the title entered by the dealer in line 3, “Date Placed in Service” field of the IRS Form 8936! That seems correct and honest. 🙂
Okay, I guess my situation is different because the vehicle was not at the dealership, it was at another dealership that was over 100 miles away that they share inventory with. My dealership said that without the contract signed they couldn’t even request the car from the other dealership. I guess their agreement is to trade cars, but because they are separate dealerships my dealership actually has to get the car moved to their dealership and “land it” which they said means they have to take ownership from the other dealer and put the car in their dealership ownership/name before they can actually let me take physical delivery and drive it off the lot. The other dealership is actually closer to me, so I had originally asked if I could pick it up at the other dealership, but again because my dealership doesn’t own the car until they received it on their lot, I have to wait for them to transport it, land it, and make it available for me to pick up at their dealership. Not sure how you interpret that or if you even care to 😀, but that is what I’m dealing with in trying to figure out if I am eligible to claim the tax credit since my goal is not to commit tax fraud.And that date should be the same date you showed up, signed the paperwork, and took home the car - or left it at the dealer for some reason. The dealer can't make up a date.
Thanks…that is the conclusion I have been getting to, too. I can’t believe the IRS meant to make Line 3 of Form 8936 so unbelievably complicated to need a legal, tax, and department of motor vehicles scholar to interpret, the definition of “Date Placed in Service”. 🙂😀Life is really complicated if you try hard enough. When you fill out your form just put in the date that you take possession of the stupid car and stop worrying.
Agreed. I purchased a MME on 11/30 (as in signed, paid, and drove away), but haven't received the registration, plates, or title yet. It seems obvious to me that this is the only date that matters. It can't be the title because if you get a loan, you don't have the title until it is paid off years later. Having said that, I have not yet read the IRS form, but the purchase date is clearly the "date put in service" as far as anyone should be concerned.Thanks…that is the conclusion I have been getting to, too. I can’t believe the IRS meant to make Line 3 of Form 8936 so unbelievably complicated to need a legal, tax, and department of motor vehicles scholar to interpret, the definition of “Date Placed in Service”. 🙂😀
