This notice announces the credit phase-out schedule for advanced lean
burn technology motor vehicles and hybrid passenger automobiles and light
trucks manufactured by Toyota Motor Corporation.
Section 30B(a)(2) of the Internal Revenue Code provides for a credit
determined under § 30B(c) for certain new advanced lean burn technology
motor vehicles. Section 30B(a)(3) provides for a credit determined under
§ 30B(d) for certain new qualified hybrid motor vehicles. Both
the new advanced lean burn technology motor vehicle credit and the new qualified
hybrid motor vehicle credit begin to phase out for a manufacturer’s
passenger automobiles and light trucks in the second calendar quarter after
the calendar quarter in which at least 60,000 of the manufacturer’s
passenger automobiles and light trucks that qualify for either credit have
been sold for use or lease in the United States (determined on a cumulative
basis for sales after December 31, 2005). Taxpayers purchasing the manufacturer’s
vehicles during the first two calendar quarters of the phase-out period may
claim only 50 percent of the otherwise allowable credit. Taxpayers purchasing
the manufacturer’s vehicles during the third and fourth quarters of
the phase-out period may claim only 25 percent of the otherwise allowable
credit. No credit is available for vehicles purchased after the last day
of the fourth quarter of the phase-out period.
Notice 2006-9, 2006-6 I.R.B. 413, provides procedures for a vehicle
manufacturer (or, in the case of a foreign vehicle manufacturer, its domestic
distributor) to certify to the Internal Revenue Service (Service) both (1)
that a particular make, model, and model year of vehicle qualifies for either
the new advanced lean burn technology motor vehicle credit or the new qualified
hybrid motor vehicle credit and (2) the amount of the credit allowable with
respect to that vehicle.
Section 5.05 of Notice 2006-9 requires a manufacturer (or, in the case
of a foreign vehicle manufacturer, its domestic distributor) that has received
from the Service an acknowledgement of its certification for a particular
make, model, and model year of vehicle to submit to the Service a report of
the number of qualified vehicles sold by the manufacturer (or, in the case
of a foreign vehicle manufacturer, its domestic distributor) to retail dealers
during the calendar quarter. A qualified vehicle is defined for this purpose
as any passenger automobile or light truck that is a new advanced lean burn
technology motor vehicle or a new qualified hybrid motor vehicle.
In accordance with the section 5.05 of Notice 2006-9, Toyota Motor Sales,
U.S.A., Inc. has submitted quarterly reports that indicate that its cumulative
sales of qualified vehicles to retail dealers reached the 60,000-vehicle limit
during the calendar quarter ending June 30, 2006. Accordingly, the credit
for all new advanced lean burn technology motor vehicles or new qualified
hybrid passenger automobiles or light trucks manufactured by Toyota Motor
Corporation will begin to phase out on October 1, 2006.
SECTION 3. SCOPE OF NOTICE
This notice applies to any make, model, or model year of new advanced
lean burn technology motor vehicle or new qualified hybrid passenger automobile
or light truck that is—
(1) manufactured by Toyota Motor Corporation; and
(2) purchased for use or lease in the United States on or after October
1, 2006.
.01 In general. If a new advanced lean burn technology
motor vehicle or new qualified hybrid passenger automobile or light truck
manufactured by Toyota Motor Corporation is purchased for use or lease after
September 30, 2006, the allowable credit is as follows:
(1) For vehicles purchased for use or lease on or after October 1, 2006,
and on or before March 31, 2007, the credit is 50 percent of the otherwise
allowable amount determined under § 30B(c) or (d) (whichever is
applicable);
(2) For vehicles purchased for use or lease on or after April 1, 2007,
and on or before September 30, 2007, the credit is 25 percent of the otherwise
allowable amount determined under § 30B(c) or (d) (whichever is
applicable); and
(3) For vehicles purchased for use or lease on or after October 1, 2007,
no credit is allowable.
.02 Certified Vehicles. The following tables set
forth the credit available on or after October 1, 2006, for hybrid motor vehicles
for which Toyota Motor Sales, U.S.A., Inc. received an acknowledgement of
its certification from the Service on or before September 19, 2006:
The principal author of this notice is Nicole R. Cimino of the Office
of Associate Chief Counsel (Passthroughs and Special Industries). For further
information regarding this notice, contact Ms. Cimino at (202) 622-3120 (not
a toll-free call).
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