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Tax Strategy: Updates on the Clean Vehicle Tax Credit

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The requirements for the Clean Vehicle Credit seemed a little complicated when they were introduced in the Inflation Reduction Act in 2022, and they are proving to be a little difficult in practice. 

There were restrictions based on where the vehicle was assembled and where the critical minerals and battery components originated. Then there were limits on the manufacturer’s suggested retail price for the vehicle and the income of the purchaser. The manufacturer was required to have vehicles pre-approved for a given level of credit and the dealer was required to be registered.

Some provisions were phased in over time, including the option to transfer the credit to the dealer, which became effective for 2024. The Internal Revenue Service then added certain compliance requirements, including filing a time of sale report (the Clean Vehicle Seller Report (Form 15400)) within 72 hours of the vehicle being placed in service and submitting information through an Energy Credits Online portal.

Plug-in vehicle parking spot

Some of these provisions were designed to simplify the process. When a potential purchaser entered the showroom, the purchaser would be able to find out in real time what amount of credit was associated with a particular vehicle. A time-of-sale report could be filed with the IRS electronically via the portal to determine even before the sale was finalized if the vehicle qualified for the credit. 

Unfortunately, things have not worked out quite so well in practice. 

The more simplified requirements in place for purchases in 2023 appear to have lulled dealers into the belief that the same practices would be fine for 2024. Some dealers, far from using the time-of-sale reports to make sure the credit was cleared for approval at the time of sale, failed even to prepare the reports. Purchasers, unaware of the new requirement, failed to demand a copy at the time of sale. In those instances where the purchaser retained entitlement to the credit, rather than transferring it to the dealer, the purchaser found that, when they filed their 2024 tax return in 2025, the IRS rejected the claim for the credit. When the purchaser contacted the dealer about the problem, the dealer found they were unable to correct the issue because the time-of-sale report had not been filed within the required 72-hour period and any late submission was rejected as untimely. 

Only 7% of purchasers in 2024 retained their entitlement to the credit. The rest of the purchasers transferred entitlement to the credit to the dealer, resulting in a price rebate on the vehicle purchase. However, again, when the dealer sought to claim the credit transferred from the purchaser, the dealer encountered the same problem of an untimely time-of-sale report, which could not be corrected because the 72-hour time period had expired.

This glitch in the system impacted dealers even more than purchasers and got the attention of the National Automobile Dealers Association, which immediately started pressuring the IRS and Congress to find a solution to the problem. In response, the IRS has informed NADA that it is waiving the 72-hour requirement and is accepting late time-of-sale reports into the Energy Credits Online portal. The IRS has set no time limits so far on the submission of late reports.

Corrective action

Dealers will want to refile all rejected time-of-sale reports that had been rejected as untimely. Dealers will also want to make sure they are registered with the IRS and notify any purchasers that the credit has now been approved. 

Purchasers will want to contact the dealer for a copy of the time-of-sale report and make sure the dealer is resubmitting the report or submitting it for the first time. Purchasers will need to file a Form 8936, “Clean Vehicle Credits,” to be used for the Clean Vehicle Credit, the Previously Owned Clean Vehicle Credit and the Qualified Commercial Clean Vehicle Credit. Form 8936 is required to be filed either when the purchaser is claiming the credit on the purchaser’s tax return or when the purchaser has transferred the credit to the dealer. 

In some cases, where the purchaser had already filed a tax return where the credit was rejected by the IRS, the purchaser will be required to file an amended tax return to claim the credit once the time-of-sale report has been accepted.

Termination of the Clean Vehicle Credit

While under current law, the Clean Vehicle Credit is scheduled to continue until 2032, Congress is working on tax legislation expected to be enacted this year that might repeal the credit. President Trump has expressed his opposition to many of the clean energy credits included in the Inflation Reduction Act enacted in 2022, and in particular opposition to the Clean Vehicle Credit. 

Congress is still in the early stages of working on this legislation, and it is not clear to what extent this provision might be included in the final legislation. If enacted at all, it is likely that the legislation would not be enacted until later in 2025. This makes it unlikely that any repeal of the Clean Vehicle Credit would be made retroactive to the beginning of 2025. However, it is possible repeal could be effective as of the enactment date of the legislation. 

Taxpayers considering the purchase of an electric vehicle in 2025 may want to monitor the progress of this tax legislation through Congress and whether a repeal of the clean vehicle credit appears to be included. Purchase of the vehicle before enactment of the legislation may preserve the credit for the taxpayer. 

Tariffs

The limit on the manufacturer’s suggested retail price for electric vehicles could become more difficult for manufacturers and dealers to stay under if the tariffs on imported automobiles and auto parts force manufacturers to raise prices. The MSRP limit for vans, SUVs and pick-ups is $80,000 and for other vehicles $55,000. If the electric vehicle currently under consideration for purchase is close to these price limits, a taxpayer might want to consider purchasing the vehicle sooner, before these tariffs achieve their full impact.

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Accounting

FASB Standardizes Carbon Offsets Accounting Rules

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FASB Standardizes Carbon Offsets Accounting Rules

In a decisive move toward standardized environmental financial reporting, accounting standards boards issued updated implementation guidance during the week ending July 25, 2026, regarding the formal recognition and valuation of corporate carbon offsets and environmental credits. The revised frameworks establish precise rules for how enterprises must measure, record, and disclose carbon credits on balance sheets, eliminating years of inconsistent reporting practices across public capital markets.

Under the finalized accounting standard, purchased carbon offsets can no longer be categorized under vague administrative expenses or unstandardized intangible asset accounts. Instead, organizations must classify environmental credits based on underlying operational intent—distinguishing between credits held for immediate compliance compliance obligations, long-term offset obligations, or active market trading. Furthermore, companies are required to evaluate carbon holdings for fair value impairment at the end of each reporting period, ensuring that depreciated or low-quality environmental credits do not distort corporate asset values.

The standardized rules carry significant implications for corporate audit committees and chief accounting officers. External audit firms are implementing rigorous verification protocols to validate the physical legitimacy, legal ownership, and scientific permanence of carbon credits claimed on balance sheets. Inaccurate or overstated carbon accounting claims now carry substantial financial litigation risk, alongside potential regulatory enforcement for misleading ESG disclosures.

To remain fully compliant, corporate accounting departments must establish centralized carbon tracking systems integrated into primary standard ERP ledgers. Accounting teams that proactively adopt standardized environmental reporting protocols will build investor credibility, streamline annual audit processes, and insulate their organizations against evolving regulatory scrutiny.

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Accounting

Automated Tax Compliance Tools Reduce Risk

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Automated Tax Compliance Tools Reduce Risk

Corporate tax departments reached a critical juncture in automated operational management. With nations worldwide rapidly enacting digital service taxes, localized value-added tax (VAT) mandates, and real-time electronic invoicing requirements, manual tax calculations have become obsolete. Modern corporate tax divisions are aggressively deploying AI-driven tax engine software to automate complex cross-border indirect tax calculations in real time.

The imperative for automated tax compliance stems from the sheer complexity of current trade policies and multi-jurisdictional commerce. E-commerce platforms, software vendors, and global manufacturers face constantly changing regional tax rates, statutory exemption rules, and cross-border tariff structures. Automated tax engines embed directly into enterprise enterprise resource planning (ERP) architectures, automatically applying correct tax codes at the point of sale, calculating real-time withholding amounts, and generating compliant e-invoices.

Automated audit trail generation represents another key advantage of modern tax tech integration. Advanced compliance platforms log every transactional tax determination on immutable digital ledgers, providing tax authorities with transparent, self-verifying audit trails. This capability drastically reduces the operational duration and administrative cost of corporate tax audits, protecting enterprises against severe penalties resulting from calculation errors or missed reporting deadlines.

For chief financial officers and tax directors, investing in automated tax compliance is a vital operational risk mitigation strategy. Automating routine tax calculations frees high-level accounting professionals to focus on strategic tax planning, transfer pricing optimization, and risk management in an increasingly complex global economic environment.

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Accounting

Continuous Auditing Transforms Corporate ERPs

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continuous auditing transforms corporate erps

As corporate accounting departments cross the threshold into late July 2026, the adoption of continuous, automated auditing systems has reached a definitive turning point. Driven by advances in artificial intelligence and deep integration with modern Enterprise Resource Planning (ERP) platforms, leading finance organizations are moving away from traditional, periodic post-hoc audits in favor of real-time, 100% transactional verification. This technological transition is redefining internal control environments, reducing compliance costs, and eliminating the structural delays inherent in legacy quarterly closing processes.

Unlike traditional auditing frameworks that rely on statistical sampling—a process that inevitably leaves operational blind spots—continuous auditing software monitors operational data feeds continuously. Every purchase order, electronic invoice, payroll disbursement, and cross-border wire transfer is automatically cross-referenced against established corporate governance parameters, regulatory tax schedules, and anti-fraud algorithms in real time. Anomalies or unauthorized ledger entries are flagged instantly, allowing internal audit teams to investigate and remediate compliance gaps immediately rather than months after the close of a financial period.

The implications for executive financial management are far-reaching. By embedding continuous verification directly into daily transaction workflows, chief financial officers gain uninterrupted visibility into the organization’s true financial standing. Real-time balance sheet auditing eliminates the severe operational bottlenecks associated with month-end and quarter-end financial reconciliations, freeing accounting professionals to focus on strategic financial modeling, tax planning, and capital allocation rather than manual data entry and spreadsheet consolidation.

However, implementing continuous auditing requires accounting leadership to invest heavily in data governance and technical upskilling. Internal audit teams must evolve from manual ledger reviewers into system architects capable of auditing complex algorithms and validating automated data pipelines. Accounting firms and corporate controllers that master continuous auditing will establish a resilient compliance framework capable of meeting stringent international regulatory standards with total transparency.

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