Based on the IRS guidelines and recent developments:
Corrected time-of-sale reports can be submitted after the 3-day deadline for original submissions, but the process is subject to IRS review and potential delays. While no explicit penalties are mentioned in the provided documents, dealers face operational and financial risks:
- Reimbursement delays: The IRS may withhold advance payments until completing reviews.
- Customer issues: Buyers may be unable to claim credits if reports are missing or unprocessed.
- Registration risks: Persistent non-compliance could lead to ECO portal registration revocation.
The IRS temporarily suspended the 3-day deadline for 2024 submissions in late 2024, allowing late filings with explanations, but emphasized prompt submission. For transactions beyond this temporary relief period, dealers must still provide valid explanations for delays and are subject to IRS scrutiny.
Key documentation required includes buyer attestations, credit transfer elections, and AGI limitation disclosures. Dealers with pending registrations or unresolved ECO portal issues remain particularly vulnerable to processing delays.
(Sources: IRS Rev. Proc. 2023-33, NHADA updates)
Original article by NenPower, If reposted, please credit the source: https://nenpower.com/blog/are-there-any-penalties-for-dealers-who-submit-corrected-time-of-sale-reports-late/
