Pre-Filing Registration

Taxpayers are required to register their intent to make an elective payment or transfer election for such election to be valid. After receiving the registration number(s), the election must be made on a timely filed return (including extensions). This User Guide focuses on the pre-filing registration process. Detailed information about the credits, how they are computed, and how they are reported is available in IRS forms, form instructions, and other resources. See Appendix B – Elective Pay and Transfer Election Resources.

Complete and submit the pre-filing registration request no earlier than the beginning of the tax year in which the taxpayer will earn the credit it wishes to monetize with an elective payment election or transfer election. This is the earliest date for pre-filing registration because the facility/property that will generate the credit (either as an investment or as a production facility) must have been placed in service before the taxpayer can register it for an elective payment or transfer election.

! Plan Ahead: Register 120 Days Early !

Even though registration is not possible prior to the beginning of the tax year in which the credit will be earned, the IRS recommends that taxpayers register as soon as reasonably practicable during the tax year. The current recommendation is to submit the pre-filing registration at least 120 days prior to when the organization or entity plans to file its tax return. This should allow time for IRS review, and for the taxpayer to respond if the IRS requires additional information before issuing the registration numbers.

A registration submission can be amended or a property can be removed from a registration after a prior submission has been processed by the IRS and returned. Amendment can be used to change information provided in the original submission such as the removal of one or more previously submitted (but not approved) properties, or addition of new properties. To update information on a previously approved property, the registration for the property must be cancelled and the property re-added. To add more properties, an existing submission package can be amended, or a new package (up to 33 packages, per subsidiary if applicable) can be created. Note: Please do not register the same property in more than one registration package.

Other important considerations:

• The IRS generally reviews and processes registration submissions through the registration tool in the order it receives them. A registrant cannot request expedited handling.

• IRS may consider a registrant’s tax period ending date when managing the pre-filing registration caseload.

• As a return filing deadline for a type of entity approaches, the review team may prioritize review of registrations submitted by those types of entities to get registration numbers in order to meet filing deadlines. In such cases, elective payment registrants should anticipate that the tax return on which the elective payment is made may undergo heightened scrutiny to mitigate the risk of fraud and duplication that pre-filing registration is intended to address before a payment is issued.