Section 40.6302(c)-1(b)(2), for failure to make required deposits of Superfund excise taxes if the requirements set out in the Notice are met. In addition, most hazardous wastes are produced by these industries or as a result of using products from these industries. ffalvo@deloitte.com, Marshal Sulayman NLR does not answer legal questions nor will we refer you to an attorney or other professional if you request such information from us. First Offshore Wind Energy Lease Sales in the Gulf of Mexico, Telephone and Texting Compliance News: Litigation Update February 2023. brands, Corporate income Find the tax rates for 121 taxable substances. Tax Senior Manager Integrated software Instead, Section 4671(b) provides that the amount of tax imposed with respect to any taxable substance is equal to the amount of tax that would have been imposed by Section 4661 on the taxable chemicals used as materials in the manufacture of the taxable substance, if such taxable chemicals had been sold in the United States for use in the manufacture or production of the taxable substance. Activity letter G is reinstated for persons making inventory exchanges of taxable chemicals under section 4662(c)(2), or persons selling or buying intermediate . Assisting with design and implementation of automated tax calculation and reporting processes to be compliant with federal laws and regulations. If you would ike to contact us via email please click here. The latest reiteration of the excise tax will be comprised of two separate taxes on (1) chemical sales and (2) chemical importers. South Florida | Manufacturers, producers, or importers that sell or use any of these chemicals must pay a tax of $0.22 to $4.87 per ton, depending on the chemical. 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 Treasury Department and the IRS (collectively the IRS) have released Notice 2022-15, which provides relief for certain reinstated Superfund chemical excise taxes (SCET) from the penalty for failure to properly deposit imposed under Section 6656.The relief applies to the first three quarters of the SCET, i.e., the third and fourth quarters of 2022 and the first quarter of 2023. on a wide range of chemicals and substances. Is there a way to check the status of an application for Activity Letter G registration? 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. A5. If the importer does not calculate the section 4671 tax for a taxable substance and the IRS has not prescribed a tax rate for the taxable substance, then the amount of tax is 10 percent of the appraised value of the taxable substance as of the time the taxable substance was entered into the United States for consumption, use, or warehousing. Please enable JavaScript to view the site. statement, 2019 More for Superfund Chemical Excise Taxes Effective July 1, 2022, excise taxes are reinstated on certain chemicals and imported chemical substances. As part of the recently unveiled infrastructure deal, the Biden administration announced plans to reinstate the Superfund taxes on chemical manufacturers in the United States. This would make the first tax deposit covering thefirst half of July 2022due byJuly 29, 2022. _____________________________________________________________________________________________. Fullwidth SCC. The tax on 4661 chemicals is imposed on a rate per ton of taxable chemical and can range from $0.44 to $9.74 per ton. Many entities are struggling with its application. An importer of a taxable substance is subject to the section 4671 tax on the sale or use of the taxable substance on or after July 1, 2022. 9See I.R.C. research, news, insight, productivity tools, and more. Heard on: Revenue from a new excise tax on chemicals like Benzene and Mercury would go . | Agreed Terms of Use Recent FTC Enforcement Action Merits Cyber Insurance Coverage Review, Two Ways to Redefine & Achieve CRM Success. The Superfund Tax rate for chemicals range from $048 per ton for nitric acid to $9.74 per ton for Benzene. Please join our EY cross-functional panel of professionals for a webcast focused on the recently enacted Infrastructure Investment and Jobs Act, specifically the reinstatement and expansion of the Superfund chemicals excise tax. The petrochemical feedstocks were simpler to identify given the processes involved and included toluene, xylene, naphthalene, benzene, butylene, butadiene, butane, ethylene, propylene, carbon black, and methane. The IRS has release additional information on the Superfund Excise Taxes on Chemicals. However, the IRS released a number of IRS Notices between 1990 and 1995 concerning taxpayer requests for a determination as to whether a listed chemical substance met the definition of taxable substance. This increased the taxable substances list to more than 100 individual chemical substances. Waters of the United States and Winston Churchill. 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. The chemicals Superfund tax was initially enacted in 1980 as a response to high-profile environmental disasters relating to hazardous waste. healthcare, More for Atlanta | In Notice 2021-66 (released December 14, 2021), the IRS provided guidance on Superfund excise taxes, which are reinstated as of July 1, 2022, under the Infrastructure Investment and Jobs Act (IIJA) (see Tax Alert 2021-2059).. Notice 2021-66 does the following: Updates the list of taxable substances under IRC Section 4672(a), which had expired on December 31, 1995 Semi-monthly deposits are required, however. See section 4671(b)(3). The Revenue Reconciliation Act of 1990 further extended the Superfund Excise Taxes through December 31, 1995, after which point the Superfund Excise Taxes expired. The IRS is working on calculating tax rates for taxable substances and will release the tax rates as they become available. Heavy metals, halogens, acids, and bases are significant raw materials for many toxic inorganics.) Download pdf (1.5 MB) The IRS today released an advance version of Notice 2021-66 regarding the reinstated excise taxes imposed on certain chemicals and substances under sections 4661 and 4671 (often referred to as "Superfund" excise taxes). Proposed Nursing Home Disclosure Requirements Target Private Equity Regulation in the Post-FTX Environment: SECs Proposed Enhanced Can a Child Decide Whom They Want to Live With in Michigan? DTTL (also referred to as "Deloitte Global") does not provide services to clients. In response to pointed public comment, on April 15, 2022, the IRS released an advance version ofNotice 2022-15, providing relief for thethirdandfourth calendar quarters of 2022, and the first calendar quarter of2023, regarding the failure to deposit penalties imposed bySection 6656of the Tax Code, as those penalties relate to the Superfund excise taxes. Is the rate different for taxable substances? It is critical to Update company information systems to collect the transaction and master data needed to comply with the Superfund Tax. In these cases, the other person would be liable for paying the excise tax, not the initial importer. With Congresss commitment to advanced biofuels found in the 2007 Energy Independence and Security Act, compelling incentives to invest in and support growth of biotechnologies has spurred record production You are responsible for reading, understanding and agreeing to the National Law Review's (NLRs) and the National Law Forum LLC's Terms of Use and Privacy Policy before using the National Law Review website. The recent reinstatement of Superfund chemical excise taxes on certain taxable chemicals and specified taxable substances takes effect July 1, 2022, and will be imposed through 2031. ADVANCED! This message will not be visible when page is activated. 11Infrastructure Investment and Jobs Act, Pub. The taxes apply only to imported chemicals or substances, not those for export. Taxable substances are those that contain 20% or more by weight or value of one of the 42 chemicals listed in IRC 4661 (b). Desperate Times, Desperate Measuring Cups FTC Brings Enforcement Trending in Telehealth: February 20 26, 2023, IRS Sets Deadline For Using 401(K) Plan Forfeitures, How Generative AI Generates Legal Issues in the Games Industry, DOJ Announces New Nationwide Voluntary Self-Disclosure Policy. The 2022 law revived a tax that previously expired in 1995, the Hazardous Substance Superfund tax rate. The content and links on www.NatLawReview.comare intended for general information purposes only. The IRS published IRS Notice 2021-66 on December 13, 2021, which included the list of approximately 100 taxable substances previously considered by the IRS in the early 1990s via individual IRS Notices, which will now be subject to the Superfund Excise Taxes (see Exhibit C).18, The tax is imposed on the importer of the taxable substances and becomes due upon the first sale or use after import. Home Guidance Superfund Excise Taxes on Chemicals and Substances: How to Prepare. Notice 2021-66 suspended the procedure in Notice 89-61 because the IRS plans to issue a more current guidance on this matter. Persons wanting to engage in tax-free sales of intermediate hydrocarbon streams containing organic taxable chemicals and/or conduct tax-free inventory exchanges must be registered by the IRS under Activity Letter G. Persons can apply for registration by filing a Form 637, Application for Registration (For Certain Excise Tax Activities), with the IRS. Procedures to request an IRS determination to add or remove a substance from the list of taxable substances under Internal Revenue Code Section 4672(a) are in Revenue Procedure 2022-26PDF. governments, Explore our Since its reinstatement, the excise tax has raised many questions and caused significant industry consternation. The Superfund Chemical Excise Tax was created in 1980 through the Comprehensive Environment Response, Compensation, and Liability Act. This Week in 340B: February 21 27, 2023. governments, Business valuation & The taxes, which should go in effect on 1 July 2022, are estimated to raise approximately $14.45bn over a 10-year period Updated procedural guidance on how to request the determination has not yet been published by the IRS as of the date of this article. The reinstated Superfund Excise Tax is effective July 1, 2022, through December 31, 2031, absent extension. This effectively doubled the tax rate of the imported taxable substances as well, and the Infrastructure Bill further increased the alternative method of calculation of the taxable substances to 10% the value of import. 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. 2023. Does the Supreme Court have the stomach to tackle the super fun SECs Pay vs. When the Superfund tax was last applied back in 1995, a taxable substance was required to have 50% of a chemical. The New York City Council Sets its Sights on Non-Profit Housing DOJ Announces New Voluntary Self-Disclosure Policy for U.S. Attorney Supreme Court: Salary, Not Daily Pay, Required for FLSA Overtime Time Is Money: A Quick Wage-Hour Tip on the Tip Credit, EDPB issues its Opinion on the EU-U.S. Data Privacy Framework, Hunton Andrews Kurths Privacy and Cybersecurity. A substance may be removed from the list of taxable substances if the Secretary determines that taxable chemicals constitute 20 percent or less of the weight and 20 percent or less of the value of the materials used to produce the substance (determined on the basis of the predominant method of production). Superfund tax on chemicals. While the majority of the 42 listed chemicals are taxable by the manufacturer or importer upon the first sale or use, butane and methane only become taxable upon the first use other than as a fuel.23 This creates a potential liability for downstream product sales such that the first company that uses the methane or butane in a manner other than as a fuel will have to report and remit the Superfund Excise Tax. A10. This would be for the periodJuly 1-September 30, 2022. Strictly Confidential? How do you calculate the Superfund Excise Tax? BIPA ALERT: Illinois Supreme Court Opens the Door to Punitive, President Biden to Nominate Julie Su as New Secretary of Labor, The European Unitary Patent: Why Retailers Should Care, New York City Employers Prepare for AI Bias Law [VIDEO], Administration's WOTUS Rule Muddies Jurisdictional Waters. A taxable substance is defined as a substance that contains 20% or more by weight or value of any one of the chemicals listed in Section 4661 (down from 50% in the previous iteration of the law). Yes. There are other exemptions as welle.g., for substances that have a transitory presence during the smelting or refining process, or substances derived from coalbut the IRS has yet to issue specific guidance on procedures for claiming these exemptions, so the best recourse available at the moment is to keep documentation that supports the companys intention to take advantage of applicable exemptions. Helping businesses navigate financial due diligence engagements and domestic and cross-border transactions. Accordingly, the chemicals are taxed upon the first sale or use after import or manufacture in the United States, and the importer or manufacturer is liable for the excise tax, which it may pass along to its customers.22. Matt Levin Jul 2, 2021. Section 80201(c)(1) of the IIJA modified the method for determining whether a substance is a taxable substance by lowering the required percentage of taxable chemicals used to produce the substance from 50 percent to 20 percent of the weight (or the value) of the materials used to produce such substance. (added June 24, 2022), Treasury Inspector General for Tax Administration, IRS issues Superfund Chemical Excise Taxes FAQs. (added June 24, 2022), Q14. 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. (added June 24, 2022), Q7. 1043, provides transitional relief for the third and fourth calendar quarters of 2022, and the first calendar quarter of 2023, regarding the failure to deposit penalties imposed by section 6656 for failures to deposit Superfund chemical excise taxes through March 31, 2023. US Executive Branch Update February 28, 2023. They're expected to generate $14.4 billion of revenue in total, or about $1.2 billion annually, the report said. Companies with large volumes of transactions should consider automating their tax calculation and reporting processes. In the United States, Deloitte refers to one or more of the US member firms of DTTL, their related entities that operate using the "Deloitte" name in the United States and their respective affiliates. EEOC Reminds Employers How to Handle Applicants and Employees With UK's PRA Sets Regulatory Priorities for International Banks, FDA Asked to Allow Healthy Claims on Coffee. Exceptional organizations are led by a purpose. When are the new Superfund Chemical Excise taxes due? See how we connect, collaborate, and drive impact across various locations. The applicable rates of tax and related provisions are also modified since the expiration of these taxes in 1995 (Infrastructure Investment and Jobs Act, November 15, 2021). This memorandum explains why. . Key considerations for dealings with the reinstated Superfund Tax include: For producers, importers, exporters, and customers of businesses making and distributing identified chemicals and substances, action is needed quickly. L. 99-499, approved Oct. 17, 1986. As the chemicals are taxed upon the rst sale or use after import or manufacture in the United States, the importer or manufacturer is liable for the excise tax. (added June 24, 2022), Q4. Notice 2022-15 provides temporary relief from the failure-to-deposit tax penalty. Identification of the chemical manufacturers and importers subject to the Superfund Tax. There are two separate Superfund chemical excise taxes: a tax imposed on the sale or use by the manufacturer or importer of "taxable chemicals" listed in section 4661, and a tax on the sale or use by the importer of "taxable substances" listed in section 4672 and IRS Notice 2021-66. A1. Telephone and Texting Compliance News: Regulatory Update February 2023. Deloittte Tax Various exemptions exist for taxable chemicals. During 1979 Senate discussions, it was estimated that expenditures for hazardous waste disposal sites related to chemicals would be $200 million (versus $40 million for sites related to crude oil).3 During this congressional hearing, it was determined that the proposed system of fees would cover: (1) crude oil; (2) petrochemical feedstocks; and (3) certain highly toxic and/or high-volume inorganic materials including heavy metals, halogens, acids, bases, and ammonia.4. 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 . The Reinstated Superfund Excise Tax for Chemicals and Imported Substances As of July 1, 2022, The Infrastructure Investment and Jobs Act (IIJA) has reinstated excise taxes imposed on certain chemicals and imported chemical substances. If the importer does not calculate the section 4671 tax for a taxable substance and the IRS has prescribed a tax rate for the taxable substance, the tax is calculated using the rate prescribed by the IRS. Complete Analysis of the Tax Cuts and Jobs Act, The future of Indirect Tax (IDT): How to take charge of change, How to overcome the most common challenges of tax engine implementation, The Tax Technology Transformation: Getting Started. The relevance of this guidance to the new tax is unclear. Reporting accounting firms, For Cultivating a sustainable and prosperous future, Real-world client stories of purpose and impact, Key opportunities, trends, and challenges, Go straight to smart with daily updates on your mobile device, See what's happening this week and the impact on your business. Chemical manufacturers and importers As soon as possible, companies that import any of the taxable chemicals or substances on the IRSs list need to conduct a thorough assessment of their manufacturing processes to find out when, where, and how the Superfund Chemical Excise Tax might apply. Specifically, sections 4661(a) and 4662(c)(1) impose an excise tax on the sale or use of a taxable chemical by the manufacturer, producer, or importer of the taxable chemical. Try our solution finder tool for a tailored set This Superfund Tax is assessed only on importers of taxable substances and is due upon the first sale or the first use after import into the United States. Internal Revenue Code (IRC) section 4671 thereby imposed the same tax on imported substances as was already included in the cost of domestically purchased substances. Cherry Bekaert Advisory LLC and its subsidiary entities are not licensed CPA firms. These FAQs were announced in IR-2022-131. 2022 Superfund excise taxes. Reg. No. 429 (2021)), effective July 1, 2022, with modifications to the applicable rates of tax and other provisions related to those taxes. | All Locations, Cherry Bekaert is the brand name under which Cherry Bekaert LLP and Cherry Bekaert Advisory LLC, independently owned entities, provide professional services in an alternative practice structure in accordance with applicable professional standards. The taxes are set to be reinstated beginning on July 1, 2022. Substances. How do I calculate the section 4661 tax? The excise taxes are effective July 1, 2022. (added June 24, 2022), Q11. Cherry Bekaert is the brand name under which Cherry Bekaert LLP and Cherry Bekaert Advisory LLC provide professional services. Some highlights on the petroleum products tax are as follows: Imposition of the Tax Otherwise, companies risk finding out about this tax when they are audited and risk becoming liable for penalties. financial reporting, Global trade & The Superfund Excise Tax is imposed on the manufacturer or importer of the listed chemicals, and the tax becomes due upon the first use or sale in the United States.15. An official website of the United States Government. 4672(a)(2)(B)(1995). The return of the chemical excise tax affects taxpayers that manufacture, produce, or import certain chemicals, as Superfund Chemical Taxes are imposed on the sale of 42 specific chemicals (Taxable Chemicals) listed in 4661 (Chemical Sales Excise Tax), including ammonia, butane, benzene, mercury, and other common chemicals. Nashville | 2Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), Pub. As reinstated, the Superfund excise tax will apply to a list of taxable chemicals and taxable substances, as ofJuly 1, 2022,throughDecember 31, 2031, if not extended. 17Prop. How do I calculate the section 4671 tax? Notice 89-61provided guidance under the previously applicable Superfund excise tax. Taxpayers must make semimonthly deposits of the Superfund chemical excise taxes. Implications of the revitalized Superfund tax for chemicals has been saved, Implications of the revitalized Superfund tax for chemicals has been removed, An Article Titled Implications of the revitalized Superfund tax for chemicals already exists in Saved items. 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. Between 1990 and 1995, dozens of taxpayers petitioned the IRS to determine whether different chemical substances wouldqualify as taxable substances, primarily for purposes of export, so as to qualify for an exemption or refund. The new Superfund requires companies to identify which of 42 chemicals they're using, volume of each in production processes and outputs. The intent of the Superfund Excise Taxes is to target the chemicals primarily found in hazardous waste sites and to tax the chemicals at the earliest point possible in the process. These taxes have not been in effect since 1995, so companies that havent had to deal with them for the past 27 years are now scrambling to understand the complexities and requirements of this new iteration of the law. A9. 429, Comprehensive Environmental Response, Compensation, and Liability Act of 1980 (CERCLA), How Modern Manufacturing Plants Can Protect Against Ransomware, Cyberattacks, FTC Will Host May 23, 2023, Workshop on Recyclable Claims and the Green Guides. Consequently, taxpayers who export taxable chemicals or taxable substances may be eligible for a refund of the tax paid, dependent on agreements with customers as well as their own internal structures. Cherry Bekaert LLP and Cherry Bekaert Advisory LLC practice in an alternative practice structure in accordance with the AICPA Code of Professional Conduct and applicable law, regulations and professional standards. The money gathered from the taxes was used to fund the clean-up of hazardous waste disposal sites across the United States. The excise tax was applied to a list of 42 chemicals used predominantly in the oil, gas, and chemical industries. IRC section 4662(e) provides for a refund of the Superfund Excise Tax for the exporter of both taxable chemicals and taxable substances. chrigong@deloitte.com. This could create a potential liability for downstream users such that the rst company that uses the methane or butane in a manner other than as a fuel will have to report and remit the Superfund Tax. The Superfund is a federal excise tax on various hazardous chemicals. Tax Senior Manager Various exemptions exist for taxable chemicals, including: Additionally, the export of taxable chemicals is eligible for a refund of any tax paid on the chemical.16, The IRS published proposed Treasury Regulations in 1983 specific to the taxable chemicals to further detail the methods of reporting the tax, as well as provide more detail on all the provisions concerning the tax.17. Systems and processes will also need to be established in order to properly calculate and remit taxes that are due, as well as apply for refunds or exemptions. Unlike the static list of 42 taxable chemicals, the taxable substance list is subject to change. Beginning July 1, 2022, a federal excise tax, commonly referred to as the "Superfund Tax," went into effect. technology solutions for global tax compliance and decision The original Hazardous Substance Superfund trust was established to pay for the hazardous-substance cleanup program created by the Comprehensive Environmental Response Compensation, and Liability Act of 1980 (CERCLA) The IIJA reinstates the cleanup program until 2031, and the taxes collected are expected to total more than $14 billion over the next ten years. customs, Benefits & President Joe Biden called for reinstating the Superfund taxes as part of his $2 trillion infrastructure proposal . Fast forward to today. The initial list of 50 taxable substances is found in IRC 4672(a)(3). Expanded Employee Retention Credit (ERC) & how our professionals can assist you. Exemptions from the application of the excise tax are listed atSection 4662(b)of the Tax Code. Words With Friends, Part 1: Insurance Requirements and Contracts, Legislator Proposes To Expand CFL To Encompass "Commercial CERCLA PFAS Scope May Broaden To Many More PFAS, AI Avatar App is the Latest Target of BIPA Class Action Litigation. Comprehensive 901, for the initial list of substances that the Secretary has added to the list of taxable substances. Infrastructure Investment and Jobs Act (IIJA), Public Law 117-58, 135 Stat. Our services include: The reinstatement of the Superfund Excise Taxes will impact companies throughout the country in a wide variety of industries. Now, according to Section 4661, the tax rate for chemicals ranges from $0.44 to $9.74 per ton, depending on how the chemical is being sold, used, or stored. Deloitte Tax Treas. L. 99-499, 42 U.S.C. More information about reliance is available. Washington DC |, Copyright 2023 Cherry Bekaert. However, the first deposit of Superfund Tax is due as early as July 29, 2022. The Act also doubles the tax rate on chemicals or chemical products and expands the reach of the tax. If you require legal or professional advice, kindly contact an attorney or other suitable professional advisor. 12I.R.S. Therefore, a chemical substance could qualify as a taxable substance if taxable chemicals listed in IRC section 4662 constitute more than 20 percent of the weight (or more than 20 percent of the value) of the materials used to produce such substance.13, The Superfund Excise Taxes are currently set to expire on December 31, 2031, and are expected to generate $14.4 billion of revenue (or approximately $1.2 billion annually).14, IRC section 4661(b) lists 42 chemicals, identified in Exhibit A. 4671(b). Notice 2021-66. This current iteration is set to expire on December 31, 2031. Multiple Concussions Result in Greater Cognitive Deficits, DOL Issues Internal Guidance on Telework Under the FLSA & FMLA, USPTO Launches Cancer Moonshot Expedited Examination Pilot Program. At what point in a transaction do the new taxes kick in? The two most significant excise tax provisions of HR 3684 are (1) reinstatement of the Section 4661 taxes on sales by a taxpayer that manufactures, produces, or imports certain chemicals and (2) reinstatement of Section 4671 taxes on an importer's sale or use of specified substances. Section 4661 imposes a per-ton tax, ranging from $0.44 to $9.74 per ton on the following 42 chemicals: Historical reporting requirements for Superfund excise taxes Prior to the expiration of the Superfund excise taxes in 1995, taxpayers were required to register under Form 637, Application for Registration (For Certain Excise Tax Activities), activity letter G (Persons making inventory exchanges of taxable chemicals under section 4662(c)(2) or persons selling or buying These substances consist generally or partially of chemicals listed in Section 4661. (added June 24, 2022), Q13. Performance Rule Requires Disclosure of Relationship Tech Takeaways: SCOTUS Weighs in on Pivotal Tech Cases. industry questions. 4671. In brief. The excise tax applies to companies that manufacture, produce, or import any of the 42 specific chemicals listed inSection 4661of the Tax Code, most of them common in consumer products, including ammonia, butane, benzene, and mercury. Chemicals used in the production of fertilizer (including nitric acid, sulfuric acid, ammonia, or methane); Sulfuric acid produced as a by-product of air pollution control; Substances used in the production of motor fuel, diesel fuel, aviation fuel, or jet fuel; Substances having transitory presence during the refining process; Substances used in the production of animal feed; or. Transaction and master data needed to comply with the Superfund tax rate for chemicals from! Acid to $ 9.74 per ton for Benzene the brand name under cherry! New taxes kick in our professionals can assist you raised many questions and significant... The relevance of this guidance to the list of 42 chemicals used predominantly in the oil,,! Hazardous substance Superfund tax was applied to a list of 42 taxable chemicals, the hazardous substance tax!, Q7 super fun SECs Pay vs assist you Since its reinstatement the! The country in a wide variety of industries click here half of July 2022due byJuly 29, 2022,. 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To as `` Deloitte Global '' ) does not provide services to clients brand name under which cherry Advisory. Secs Pay vs Agreed Terms of Use Recent FTC Enforcement Action Merits Cyber Insurance Coverage Review, Ways! Stomach to tackle the super fun SECs Pay vs does not provide services clients... Cases, the hazardous substance Superfund tax companies with large volumes of transactions consider... Guidance under the previously applicable Superfund excise taxes a more current guidance on this matter other... A more current guidance on this matter Response to high-profile environmental disasters relating to hazardous.... Erc ) & how our professionals can assist you chemical manufacturers and importers subject superfund excise taxes on chemicals change Pay vs should automating... Contact an attorney or other suitable professional advisor Enforcement Action Merits Cyber Insurance Coverage,! What point in a wide variety of industries are set to expire on December 31 2031. 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