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Recently, the IRS released guidance on the transferability rules and asked for comments. Atheva has recently made a submission. The comments focus on three topics. First, we ask them to switch gears and place the burden of recapture on the seller. We recognize that we're probably swimming uphill here but it can't hurt to try. Second, we asked for a timeline for registration numbers so that the IRS has to provide a registration number within a certain period of time once information has been submitted. Third, we ask for any documentation requirements be tailored to the credit size so that smaller credit sizes are not burdened with the same requirements as larger credit sizes.
A copy of our comments can be accessed here.
