IRS Issues Interim Guidance on 637 “G” Registration for Taxable Chemicals

Recent IRS guidance on registration tests for certain Form 637, Application for Registration (For Certain Excise Tax Activities), impacts taxpayers who are required to obtain a “G” registration under the reinstated Superfund Tax (effective July 1, 2022).

The Internal Memorandum updates the Internal Revenue Manual to be used by IRS Examiners when reviewing applications. Specifically with respect to the “G” registration, the guidance sets down that all applications for this letter designation are to be treated as new registrations, irrespective of whether a taxpayer may have had this designation prior to the expiration of the Superfund Tax in 1995. Additionally, the G letter designation will only be issued to taxpayers who either make inventory exchanges of taxable chemicals or buy/sell intermediate hydrocarbon streams. Where both parties to a transaction involving these activities are registered, the transaction may be conducted tax free. The letter G designation is not for importers or manufacturers of taxable chemicals not engaged in these activities.

The Memorandum also states that applicants for a letter G designation need to show a satisfactory tax history. A satisfactory tax history is demonstrated through showing a good history of filing, deposits, payments, reporting and claims.

For assistance with preparing your Form 637 “G” Registration, or to determine whether or not your business qualifies, contact us. We are here to help.

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