In the meantime, reach out to your RKL advisor with questions or to discuss your companys specific circumstances. View Full Firm Disclosure. Tax News & Views, our current events-focused tax podcast, can help provide clarity on the latest tax news and developments that could affect your business. (added June 24, 2022), Q4. New Jersey enacted a new tax law (A.B. As noted above, importers are not required to use the IRS-prescribed tax rates for the section 4671 tax and may calculate their own rates. During the first, second, and third calendar quarters of2023, the IRS will not withdraw a taxpayers right to use the deposit safe harbor rules of the Excise Tax Procedural Regulations at 26 C.F.R. See Section 4671(b)(2). - January 2023 Edition. During her free time Elizabeth enjoys going to concerts, traveling, hanging out with her pets, and caring for her succulent plants. FS-2022-31, June 2022. Operating now under a new set of rules, organizations manufacturing or importing certain chemicals now face new tax challenges. This initiative came to be commonly known as the Superfund Excise Tax on Chemicals. While the majority of the listed chemicals are taxable by the manufacturer or importer upon the rst sale or use, butane and methane only become taxable upon the rst use other than as a fuel. Aerojets previous disposal and operating practices led to soil and groundwater contamination. A13. Additionally, prior versions of these FAQs will be maintained on IRS.gov to ensure that taxpayers, who may have relied on a prior version, can locate that version if they later need to do so. Additional exemptions exist for substances taken from coal or substances present during the smelting or refining process, however, the IRS has yet to give guidance on obtaining these exemptions. Accordingly, a manufacturer, producer, or importer of a taxable chemical is subject to the section 4661 tax on the sale or use of the taxable chemical on or after July 1, 2022. Infrastructure Investment and Jobs Act (IIJA), Public Law 117-58, 135 Stat. Cherry Bekaert Advisory LLC and its subsidiary entities are not licensed CPA firms. The IRS recently issued FAQs and published tax rates for 121 of the 151 taxable substances. WebEffective July 1, 2022, Congress has revived the Superfund Excise tax on Taxable Chemicals and Taxable Substances that previously existed from 1980 through 1995. There are 42 chemicals listed in section 4661(b). Raleigh | In order to pay for the provisions in The Infrastructure Investment and Jobs Act (also referred to as the Bipartisan Infrastructure Bill), Superfund was reinstated with double the tax rate on chemicals and a vast expansion of substances. IRC 4671 imposes the excise tax on the sale or use by an importer of specified taxable substances (as initially identified in IRC 4672(a)(3) and IRS Notice 2021-66). SECURE 2.0 Series Part 3: Retirement Plan Required Minimum Court Affirmed Summary Judgment For A Financial Advisor Due To The AUSTRALIA: ASIC Starts 2023 With Focus On Greenwashing. Are Your Companys Year-End Compensation Accruals Tax Deductible? A12. The Superfund excise taxes are part of Subtitle D, Chapter 38 of the Tax Code. Taxable substances are those that contain 20% or more by weight or value of one of the 42 chemicals listed in IRC 4661(b). Notice 2021-66 does not specify the tax rate for each taxable substance. An exporter who did not pay the initial assessment of the Superfund Tax may still be entitled to the refund if certain condition are met. The taxes apply to any taxable chemical under Internal Revenue Code (IRC) 4661 and any taxable substance under IRC 4671. Retailer's Wholesale Cost ($1,000 + $200) $1,200.00. Notice 2021-66 suspended the existing procedure inNotice 89-61for an importer or exporter to petition the IRS to add or remove substances from the list, pending the issuance of additional guidance. Since the Superfund excise tax expired almost three decades ago, the industrial chemical communitys familiarity with their application is attenuated at best. Charter Brokerage is the only company that will work with the client through the entire process of maximizing your credits. It is not clear that that the IRS can offer any more relief to taxpayers than has already been given in Notice 2022-15. There are two separate Superfund chemical excise taxes: a tax on the sale or use of "taxable chemicals" under section 4661 of the Internal Revenue Code and a tax on the sale or use of imported "taxable substances" under section 4671 (all section references are to the Internal Revenue Code unless otherwise stated). A10. Nursing Homes Brace for Reforms and Heightened Government Scrutiny. Partner, Tax Controversy and Regulatory Services, PwC US. WebEarlier Superfund excise taxes were 9.7 cents per barrel of crude oil or refined oil products, and a variety of excise taxes, ranging from $0.22 to $4.87 per ton on some 42 chemicals and metal compounds. The IRS is working on calculating tax rates for taxable substances and will release them as they become available. Normally, if a taxpayer deposits less than 95% of its required deposit and is not following the prescribed safe-harbor method, Section 6656 imposes a penalty that reaches its maximum rate of 10% after only 15 days. Gas tax holiday: impact of changes in motor fuel tax rates, Tax automation: the ultimate guide to tax process efficiency, Reporting | Careers Applicability The Superfund Chemical Tax is made up of two parts: a chemical tax and a chemical substance tax. Attorney Advertising Notice: Prior results do not guarantee a similar outcome. The choice of a lawyer or other professional is an important decision and should not be based solely upon advertisements. Please reach out to our team if you have any questions about the implications of the infrastructure bill. The excise tax was not only brought back, but the IIJA doubled the prior tax rate on chemicals. How to How to Turn Your Tweets Into LinkedIn and Instagram Social What is Document Processing? Substances. However, given the related compliance processes that need to be established (e.g., automating data capture, gathering exemption documentation, and return preparation and filing) and matters that need to be addressed (e.g, Form 637 registration and taxable substance listing), taxpayers should consider taking this opportunity to evaluate whether their overall SCET program is sufficiently robust and meets the greater needs of their organization for example, by reprioritizing activities within their project plans. This would make the first tax deposit covering thefirst half of July 2022due byJuly 29, 2022. See section 4671(b)(3). Due to the complicated nature of the tax assessments, and the detailed information required, gaps in existing systems and processes may exist. See questions 4-5 for more information on taxable substances and questions 7-9 for more information on calculating the tax imposed by section 4671 (section 4671 tax). The Reinstated Superfund Excise Taxes. A Superfund tax is imposed when a taxable chemical is imported, or is domestically produced for sale or use unless an exemption applies. However, Notice 2022-15, 2022-18 I.R.B. Companies may also rely on the absence of a clear inclusion of articles in the statute and the exclusion of articles under the previous application of the Superfund excise tax. All Rights Reserved. The excise tax collection expired in 1995 but resumed on July 1, 2022. This TaxWatch webcast discusses the superfund excise taxes being reinstated, effective July 1, 2022. Any manufacturer, producer, or importer of a taxable chemical is subject to the superfund excise tax. That authority expired in 1995. In 2022, IRS received petitions to add polyoxymethylene and polyphenylene sulfide to the list of Charter is different from tax teams because we dont just focus on compliance we also find the credits your company qualifies to receive. 2022 Global Digital Trust Insights Survey, Application Security and Controls Monitoring Managed Services, Controls Testing and Monitoring Managed Services, Financial Crimes Compliance Managed Services, Virtual Business Office services for healthcare. | Privacy Policy As this question is likely to arise in the near future when the Superfund excise tax applies, the IRS can be expected to address this aspect. This law levies taxes on the manufacture, production, or importation of 42 specific chemicals and another 121 chemical This field is for validation purposes and should be left unchanged. This excise tax, which is imposed on certain chemicals and imported chemical substances, was reinstated effective July 1, 2022, as part of the Infrastructure Investment and Jobs Act of November 2021. As reinstated, the tax rates of chemicals have doubled from the amounts in the previous iteration of the Superfund tax, applied in the 1980s and 1990s. Under certain state laws the following statements may be required on this website and we have included them in order to be in full compliance with these rules. However, the first Biobased chemicals and biofuels have taken root thanks to both popular appeal and political support. See the full disclaimer. WebWork with outside vendor on Superfund Excise tax compliance; Ascend Performance Materials is the premium provider of high quality chemicals, fibers and plastics. The Superfund Tax that was established over two decades ago and taxed specific chemicals and hazardous substances has been restored after the passing of the Infrastructure Investment and Jobs Act last year. For example, the tax arising from the period July 1 - July 15, 2022 must be deposited by July 29, 2022. Any taxable chemical or substance also qualifies for a Superfund Tax Credit. These credits are accrued when a taxable chemical or taxable substance is exported. A Superfund tax is imposed when a taxable chemical is imported, or is domestically produced for sale or use unless an exemption applies. Taxable Chemicals. Pennsylvania Sales and Use Tax for Construction Contractors and Their Customers. Sightline is a tax platform that makes the entire tax process more collaborative and insightful. The This webcast discusses the three Superfund Excise Taxes that are now in place, recent trends, and hot topics to be aware of as organizations solidify processes and procedures to ensure compliance by October 31, 2022. See section 4671(b)(1). The Superfund Amendments and Reauthorization Act (SARA) of 19861995 expanded the programs scope. All rights reserved. Because these FAQs have not been published in the Internal Revenue Bulletin, they will not be relied on or used by the IRS to resolve a case. The Infrastructure Investment and Jobs Act (IIJA) reinstated the excise taxes imposed on certain chemicals and imported chemical substances under Internal Revenue Code sections 4661 through 4672 beginning July 1, 2022. The Superfund chemical taxes will be reported on Form 720, Quarterly Federal Excise Tax Return, and Form 6627, Environmental Taxes. Superfund Excise Tax on Chemicals Has Been Revived Effective July 1, 2022, Congress has revived the Superfund Excise tax on Taxable Chemicals and Taxable Substances that previously existed from 1980 through 1995. Taxpayers must meet the guidelines in the Notice to qualify for this relief. How are substances added to or removed from the list of taxable substances? The Superfund Chemicals Excise Tax Makes a Comeback. Forty-two chemicals and 151 hazardous substances are taxable; however, each is taxed differently. The Aerojet General Corp. Superfund site covers about 5,900 acres near Rancho Cordova. In order to pay for the provisions in The Infrastructure Investment and Jobs Act (also referred to as the Bipartisan Infrastructure Bill), Superfund was reinstated with double the tax rate on chemicals and a 429, Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA). There is some ambiguity in the calculation of the tax on substances, but IRS Notice 2021-66 suggests that the default tax calculation will be 10 percent of the assessed import value. Who should lead the charge? (Note that industry is requesting that the IRS establish a fixed rate by agreement between the IRS and Industry but it remains to be seen if this will be adopted by the IRS). See the full preliminary list in Internal Revenue Code 4661, 4671, 4672; Notice 2021-66. At the time of publication of these FAQs, 151 substances are listed as taxable substances. No such update has been issued to date, however. As part of this Act, superfund excise taxes imposed on chemicals and imported taxable products are set to be reinstated July 1, 2022 through Dec. 31, 2031. Are you capturing all of them? Superfund Chemical Excise Taxes Effective July 1, 2022, excise taxes are reinstated on certain chemicals and imported chemical substances. Because of potential exemptions for butane and methane used as a fuel, taxpayers further down the supply chain need to be aware of the procedural issues aecting such chemicals. On a separate notice, the IRS released the majority (121 out of 151) of the highly requested tax rates on the substances subject to the superfund chemical excise tax. The per-ton rate of tax varies depending on the taxable chemical being sold or imported, so the amount of Superfund Tax will vary by product. Statement in compliance with Texas Rules of Professional Conduct. These Superfund tax credits can be taken by either the importer, the manufacturer, or the exporter, depending on the commercial agreements that have been established among those parties. 429. At that time, the application of the tax and the deployment of funds were quite well understood, and the U.S. Internal Revenue Service (IRS) developed a relatively robust series of guidance documents to explain how the tax operated and who was subject to the tax. 11 In addition to the reinstatement of the taxes, Identify and educate key stakeholders impacted by the excise tax within the organization (supply chain, tax, EPA regulatory, IT, finance), Identify taxable chemicals, hazardous substances, and crude oil/ imported petroleum products, Identify and document exceptions to the excise tax, Forecast excise tax liability based on applicable rates, Consider filing petition with IRS to request modifications to the list of taxable substances and rate of tax on taxable substances, Assess supplier and consumer invoicing issues, Assess internal and external communications regarding excise tax information, Identify data sources required to track the lifecycle of affected chemicals and products, assess potential issues, and evaluate process and configuration changes to resolve issues, Prepare for all aspects of compliance, including filing registrations on Form 637 and filing returns on Form 720 and Form 6627. A7. (added June 24, 2022), Q6. It's important to note that the tax only applies to imported chemicals and hazardous substances. BDO USA, LLP, a Delaware limited liability partnership, is the U.S. member of BDO International Limited, a UK company limited by guarantee, and forms part of the international BDO network of independent member firms. The Superfund Excise Tax on chemical sales is back! System and Organization Control Reporting (SOC), GDPR General Data Protection Regulation. Learn how a global manufacturer increased profits by $12M in four months. Applicability of the information to specific situations should be determined through consultation with your tax adviser. The inaugural reporting for companies required to report Superfund excise taxes is on their third-quarter 2022 Form 720, due to be submitted byOctober 21, 2022. Until then, companies may take the IRS previous position as an indication of how it is likely to view articles and fabricated products under the current Superfund excise tax. In turn, the tax rate of imported substances was effectively doubled as well. PwC refers to the US member firm or one of its subsidiaries or affiliates, and may sometimes refer to the PwC network. Similarly, if an FAQ turns out to be an inaccurate statement of the law as applied to a particular taxpayer's case, the law will control the taxpayer's tax liability. Aside from this quarterly filing, taxpayers Legal Disclaimer|Privacy Policy | Copyright 2022 IGenFuels LLC. It is important for companies to be aware of the existence of this tax, and to evaluate the chemicals and substances they import, to establish whether they owe any excise taxes. Will the IRS prescribe tax rates for taxable substances? (added June 24, 2022), Q13. The Infrastructure Investment and Jobs Act (Pub.L. Companies must report the reinstated Superfund excise taxes onForm 6627, Environmental Taxes, attached toForm 720, Quarterly Federal Excise Tax Return. The hazardous substance tax will be imposed at a rate of 16.4 cents per barrel and will be adjusted for inflation on January 1 of each year until it expires on December 31, 2032. The new Superfund Chemical Tax, which is slated to expire on December 31, 2031, unless extended, is expected to yield $14.5 billion in fund revenue over the next decade or $1.44 billion each year on average. Tax is due upon the first use or first sale of a listed chemical in the United States. This legislation provided a federal Superfund to clean up hazardous-waste sites and accidents, spills, or other emergency releases of pollutants and contaminants into the environment. on The Reinstated Superfund Excise Tax for Chemicals and Imported Substances, How Finance and Accounting Outsourcing Helps Companies Grow, How Sage Intacct Real Estate Simplifies Property Management and Reporting. State Green and Sustainability Claims: A Roundtable Discussion. It is unclear whether and how the statute means to differentiate a substance from an article, and if so, whether the IRS would apply the definition of article under the Toxic Substances Control Act (TSCA). The relevance of this guidance to the new tax is unclear. Providence | Taxable substances include substances where taxable chemicals constitute more than 20 percent of the weight (or more than 20 percent of the value) of the materials used to produce such substance (as determined based on the predominant method of production). This is the first person/company at which the taxable chemical lands in the U.S. for the preceding reasons. Otherwise, companies risk finding out about this tax when they are audited and risk becoming liable for penalties. The Superfund Excise Taxes are currently set to expire on December 31, 2031. Charter Brokerage can help you mitigate the Superfund taxes paid on these taxable chemicals. The Infrastructure Investment and Jobs Act lowered this threshold to 20%. Semi-monthly deposits are required, however. IRC section 4661(b) lists 42 chemicals that are once again subject to the Superfund Excise Tax effective July 1, 2022. As a result, large and small companies alike who produce or import these chemicals or substances are about to be slammed with additional costs. See Notice 2021-66, 2021-52 I.R.B. Reconciling The IRS determined this threshold in consultation with the Environmental Protection Agency and U.S. Customs and Border Protection. This memorandum explains why. As a result, Notice 2022-15 provides that SCET taxpayers will be deemed to have satisfied the reasonable cause standard and no Section 6656 penalty will be imposed if (1) the taxpayer makes semimonthly deposits of SCET, even if in the incorrect amount, and (2) any deposit underpayment is paid in full by the due date for filing the Form 720, Quarterly Federal Excise Tax Return, for the applicable quarter. How does ESG fit into business strategy? The frequent and sizeable requirements of the reinstated superfund excise tax reporting can be burdensomeespecially for resource-constrained tax departments or those unfamiliar with the requirements. The National Law Review is not a law firm nor is www.NatLawReview.com intended to be a referral service for attorneys and/or other professionals. 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Industrial chemical communitys familiarity with their application is attenuated at best near Rancho.. On chemical Sales is back operating now under a new tax law ( A.B out! Irs prescribe tax rates for taxable substances, effective July 1 - July 15, 2022 ), Q6 their! Only company that will work with the Environmental Protection Agency and U.S. Customs and Border Protection lists! Lawyer or other professional is an important decision and should not be based solely upon advertisements of the Investment... This tax when they are audited and risk becoming liable for penalties its subsidiary entities are not CPA! These taxable chemicals 19861995 expanded the programs scope nature of the 151 taxable substances and will release them they!, hanging out with her pets, and may sometimes refer to the Superfund excise tax.!