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If or when you buy out the lease has no impact on anything here related to the IRA.
It does if the IRS says the transaction was a sale made to look like a lease.

I'm not really convinced by an argument of "A policy they began years before the IRA existed is continuing because of the IRA clawback concerns"

It's not important, but you can't say Tesla is the the group of those that say a flip-lease is ok under 45W since they have given no data either way.

Why?

it's the SAME lease terms they've offered on leases since long before the IRA and nobody said a thing about it.

They're leasing out a car, same as always-- and offering the option to buy out either at the end, or any time before the end- same as always.

It's ABSOLUTELY a lease to the leasing company (who becomes a seller if/when you take the buyout option). They don't know (or care!) about the intent of who they're leasing it to as long as they get their money.

It's not the same terms if they are adjusting the payments or residual based on getting the $7,500 which they only qualify for if they did not aquire it for resale. A sale within 30 days of acquisition (possibly longer) invalidates the lessor as the owner, per my interpretation.
 
It does if the IRS says the transaction was a sale made to look like a lease.

But the IRS hasn't said that.

On the other side we've got dozens of companies worth hundreds of billions-- who deal with finance and tax laws for a living with large staffs of lawyers and accountants- who have all concluded it's a lease.

You've not really made a compelling case they're all wrong.



It's not important, but you can't say Tesla is the the group of those that say a flip-lease is ok under 45W since they have given no data either way.

I don't believe I DID say that? I simply pointed out they could join that group if they changed their long-before-the-IRA policy of not allowing lease purchases.



It's not the same terms if they are adjusting the payments or residual based on getting the $7,500 which they only qualify for if they did not acquire it for resale.

But they're not doing that in any way related to the customer buying out (at all, or soon).

The lease terms assume X months of lease and include some reduction of the cap cost for everyone because the leasing companys cap cost is lower since THEY are getting a $7500 credit.

The lease terms also, as they have SINCE BEFORE THE IRA, give the customer the option to buy out the car from the lease, either at the end, or sooner.


A sale within 30 days of acquisition (possibly longer) invalidates the lessor as the owner, per my interpretation.


Isn't the 30 day thing in the personal/normal credit section- not the commercial credit section?
 
Isn't the 30 day thing in the personal/normal credit section- not the commercial credit section?
That 30 days seems to be IRS interpretation of §30D(d)(1)(B) "which is acquired for use or lease by the taxpayer and not for resale," but I haven't seen something from them regarding days of a similarly worded §45W(c)(1) "meets the requirements of section 30D(d)(1)(C) and is acquired for use or lease by the taxpayer and not for resale." So one could guess that IRS would treat them similarly because of the exact same wording or completely differently because it's a different section. 🤷‍♂️
 
I don't believe I DID say that? I simply pointed out they could join that group if they changed their long-before-the-IRA policy of not allowing lease purchases.
Again, not at all important
Your original comment was: "All the major legacy finance arms would not be putting themselves on the hook for a $7500 loss on massive #s of EV leases."
To which I agreed to only because Tesla is not legacy.

Isn't the 30 day thing in the personal/normal credit section- not the commercial credit section?
Yes, it's from the 30D section of the FAQs, from my previous post:
"Return or resale withing 30 days invalidates the 30D credit. 45W cannot be less stringent. A lease bought out within 30 days is a sale."
Return or resale withing 30 days invalidates the 30D credit. 45W cannot be less stringent. A lease bought out within 30 days is a sale.

But the IRS hasn't said that.

On the other side we've got dozens of companies worth hundreds of billions-- who deal with finance and tax laws for a living with large staffs of lawyers and accountants- who have all concluded it's a lease.

You've not really made a compelling case they're all wrong.
The IRS has an FAQ specially about that:

Q7. What happens if the clean vehicle lease agreement is recharacterized as a sale for tax purposes? (added December 29, 2022)
A7. In the event the clean vehicle lease is recharacterized as a sale, the lessee would need to determine if they are eligible to claim either a clean vehicle credit or a qualified commercial vehicle credit. The lessor would not be eligible to claim either credit because they would have engaged in a resale of the vehicle.

So it can happen.

I'm not the one who needs to convince the IRS that the car that was transfered to another taxpayer was owned by the short-term lessor for non-sale purposes.

But they're not doing that in any way related to the customer buying out (at all, or soon).

The lease terms assume X months of lease and include some reduction of the cap cost for everyone because the leasing companys cap cost is lower since THEY are getting a $7500 credit.

The lease terms also, as they have SINCE BEFORE THE IRA, give the customer the option to buy out the car from the lease, either at the end, or sooner.
Again, I'm not arguing how leases work, I'm saying a lease that only exists for a short time could reasonably be seen as a purchase, not a lease. Back to your original post:
it's what all the other car makers ineligible have done to work around it- pass through the $7500 to the lease, and allow immediate buyout of the lease- was hoping Tesla would do the same here.

How is this on its face a least and not a sale?
"Based on longstanding tax principles, the determination whether a transaction constitutes a sale or a lease of a vehicle for tax purposes is a question of fact"
In a quick turnaround situation:
Fact, person A now owns a car they had no interest in 30 days ago.
Fact, company B has no interest in the car they didn't have any interest in 30 days ago.

What needs to happen in the intervening time to make this look like a lease instead of sale?
 
but I haven't seen something from them regarding days of a similarly worded §45W(c)(1) "meets the requirements of section 30D(d)(1)(C) and is acquired for use or lease by the taxpayer and not for resale." So one could guess that IRS would treat them similarly because of the exact same wording or completely differently because it's a different section. 🤷‍♂️

I'd expect differently, since they treat the credit completely differently in nearly all other regards... (battery sourcing, income limits, tax liability needs, etc)

Yes, it's from the 30D section of the FAQs, from my previous post:
"Return or resale withing 30 days invalidates the 30D credit. 45W cannot be less stringent. A lease bought out within 30 days is a sale."

Why can't the commercial credit be less stringent? It's ALREADY less stringent on a bunch of other things (battery sourcing, income levels, etc)



The IRS has an FAQ specially about that:

Q7. What happens if the clean vehicle lease agreement is recharacterized as a sale for tax purposes? (added December 29, 2022)
A7. In the event the clean vehicle lease is recharacterized as a sale, the lessee would need to determine if they are eligible to claim either a clean vehicle credit or a qualified commercial vehicle credit. The lessor would not be eligible to claim either credit because they would have engaged in a resale of the vehicle.

So it can happen.

It can- but only if they violate any of the specific things the IRS cites as doing that--- simply allowing a buy out -at all- is not one of them.


I'm not the one who needs to convince the IRS that the car that was transfered to another taxpayer was owned by the short-term lessor for non-sale purposes.

I doubt they'll need to "convince" the IRS either.

A large legacy company doesn't generally put that much $ at risk unless they spoke to the IRS up front to clarify what they're doing is fine.


Again, I'm not arguing how leases work, I'm saying a lease that only exists for a short time could reasonably be seen as a purchase, not a lease. .....
What needs to happen in the intervening time to make this look like a lease instead of sale?


Nothing.

What I think you are conflating is the car company and the individual.

The only person the IRS cares about is the car company. THEY are the one getting the credit.

And they issued the same lease they always have with the same buyout terms.

So it's a lease. Period full stop.

The fact that some people on the other end of the lease (who did NOT get a credit) are choosing to use that buyout option more often now doesn't change anything from the IRS perspective.


Now- if you could demonstrate some sort of orchestrated attempt to defraud... like "Here's this email where Kia discusses leasing 100,000 EVs to Donald MoneyStealer, passing through the $7500 tax credits that Kia will receive, and then getting a kickback when Donald resells those 100,000 EVs" you'd have an excellent case.


But that's not this.

This is leasing companies doing business as usual, but reducing the cap cost in the lease because tax credit literally lowers their cap cost.
 
Why can't the commercial credit be less stringent? It's ALREADY less stringent on a bunch of other things (battery sourcing, income levels, etc)
The question of stringentcy is as regards the determination of acquired for resale. The IRS has said for 30D that flipping within 30 days is resale, not ownership. To then turn around and say 14 days isn't resale is hard to defend.

It can- but only if they violate any of the specific things the IRS cites as doing that--- simply allowing a buy out -at all- is not one of them.

It's not a comprehensive list "Features of a vehicle lease agreement that would make it more likely to be recharacterized as a sale of the vehicle for tax purposes include, but are not limited to"

What I think you are conflating is the car company and the individual.

The only person the IRS cares about is the car company. THEY are the one getting the credit.

And they issued the same lease they always have with the same buyout terms.

So it's a lease. Period full stop.

The fact that some people on the other end of the lease (who did NOT get a credit) are choosing to use that buyout option more often now doesn't change anything from the IRS perspective.
No conflation on my end (why did you think that?)

A lease with better terms (when acquiring at the end) than a sale is a sale.
There is the confounding issue that the credit makes it economically feasible for a lessor to offer better terms due to the credit, which the IRS would need to guide on home to structure it to not run afoul of the restriction, but the immediate buyout senario sure looks like a duck.

Now- if you could demonstrate some sort of orchestrated attempt to defraud... like "Here's this email where Kia discusses leasing 100,000 EVs to Donald MoneyStealer, passing through the $7500 tax credits that Kia will receive, and then getting a kickback when Donald resells those 100,000 EVs" you'd have an excellent case.

Now that seens like conflating. Donald is free to sell those cars. And there is no reason, based on your viewpoint as I understand it, for a kickback. The kickback value could be included in the amount of profit Kia makes on the 'lease'. If leases are fine, then 100,000 leases are fine.
 
I'd expect differently, since they treat the credit completely differently in nearly all other regards... (battery sourcing, income limits, tax liability needs, etc)
It's because those §30D requirements and limitations are explicitly not written into §45W. "Qualified commercial clean vehicle" specifically mentions "not for resale" and refers to §30D(d)(1)(C) "which is made by a qualified manufacturer" and §30D(d)(1)(D) "which is treated as a motor vehicle for purposes of title II of the Clean Air Act" but does not refer to (seemingly an unintended loophole/workaround per some lawmakers) entries like final assembly, critical minerals, battery components, MSRP limits, etc. IRS can only enforce what is actually signed into law, and that includes "not for resale."
 
It's because those §30D requirements and limitations are explicitly not written into §45W. "Qualified commercial clean vehicle" specifically mentions "not for resale" and refers to §30D(d)(1)(C) "which is made by a qualified manufacturer" and §30D(d)(1)(D) "which is treated as a motor vehicle for purposes of title II of the Clean Air Act" but does not refer to (seemingly an unintended loophole/workaround per some lawmakers) entries like final assembly, critical minerals, battery components, MSRP limits, etc. IRS can only enforce what is actually signed into law, and that includes "not for resale."


Ok- but they're not buying to resell it.

They are buying to lease it-- and as has always been the case, including year and years before the IRA existed- those leases have the option to purchase the vehicle if the person leasing wishes to. Some use that option, some don't--but all of them are people who leased the vehicle from them to start with.

It doesn't change the fact the vehicle was purchased for leasing, not resale.
 
This:
It doesn't change the fact the vehicle was purchased for leasing, not resale.

Is in conflict with this:
it's what all the other car makers ineligible have done to work around it- pass through the $7500 to the lease, and allow immediate buyout of the lease-

Did they acquire it to lease it, or acquire it to sell it? Your statement sure looks like a lease that isn't intended to be used as such. "Work around it" seals the deal.

Preventing early termination/ buyout allows it to be a lease. Not giving the lessee the benefit of the credit in residual makes it less attractive to buy out.
 
The question of stringentcy is as regards the determination of acquired for resale. The IRS has said for 30D that flipping within 30 days is resale, not ownership. To then turn around and say 14 days isn't resale is hard to defend.

It's not though.

They aren't "flipping" the car- they are leasing it.


The -consumer- is the one deciding to exercise an optional clause in the lease.



No conflation on my end (why did you think that?)

because you still seem to be mixing up "what the leasing company did" and "what the person leasing the car did"

The intent of one is not neccesarily the intent of the other-- and the intent of the leasing company is the relevant one here.

Their intent is to lease you a car... Not quickly resell cars they bought.


Now that seens like conflating. Donald is free to sell those cars. And there is no reason, based on your viewpoint as I understand it, for a kickback. The kickback value could be included in the amount of profit Kia makes on the 'lease'. If leases are fine, then 100,000 leases are fine.

The point of the kickback is to show the intent of the LEASING company that these aren't really to be leased, but all immediately purchased then resold.

That's not at all what's happening here though.

They are obtaining the cars with intent to lease.

And then leasing them.

The lease, as their leases always have, do have an option to buy it if the end user wishes to exercise that option-- but doing so speaks only to the intent of the consumer, not the leasing company.



This:


Is in conflict with this:

Not really?

They didn't just ADD the option to buy it-- it's always been there.

The only "change" is reflecting the $7500 credit in the cap cost. Which there's nothing in the law saying they can't do or magically makes it NotALease.


You'd have a lot better argument- interestingly enough- if they'd all previously operated like Tesla-- where leases COULD NOT be bought out at all... and suddenly only added that option along with IRA discounts.

Instead the general terms and nature of the lease has not change at all

So if it's "not really a lease" if you can buy it out then it was never a lease- going back years and decades-- which I'm sure you'll agree is ridiculous?



Did they acquire it to lease it, or acquire it to sell it? Your statement sure looks like a lease that isn't intended to be used as such. "Work around it" seals the deal.

It doesn't though.

It works around the issue buyers have no way to access any benefits of the credit... but the ability to do that via lease is explicitly in the law
 
The -consumer- is the one deciding to exercise an optional clause in the lease
Yes, and the business is the one who put in the lease buyout clause. IRS has plenty of experience with leases outside of vehicles such as wider equipment and property in general. Even outside of leases, parties involved can call a transaction one thing, but IRS could look at intention, how things are structured, likelihood of something happening, etc. to treat it as something else, e.g., a sale.

IRS might even start from reports like "EV LEASING | Expected to Rise Further in 2024" (Cox Automotive Industry Insights 2024 PDF page 25) where in 2023, EVs went from under 10% leases (-5% vs industry) to nearing 25% (+5% vs) to decide if they should put effort into investigating what percentage should actually be recharacterized as sales. Then again, perhaps these numbers show that the IRS shouldn't bother because clearly so many businesses are leasing EVs and must be doing the right thing and not worth their time?

As the laws are now, §30D incentivizes locally-made EVs while §45W incentivizes commercial usage of EVs, and both seem to align with accelerating the transition to sustainable energy with Tesla making use of both.
 
because you still seem to be mixing up "what the leasing company did" and "what the person leasing the car did"

The intent of one is not neccesarily the intent of the other-- and the intent of the leasing company is the relevant one here.

Their intent is to lease you a car... Not quickly resell cars they bought.

So if it's "not really a lease" if you can buy it out then it was never a lease- going back years and decades-- which I'm sure you'll agree is ridiculous?

It works around the issue buyers have no way to access any benefits of the credit... but the ability to do that via lease is explicitly in the law

As a seller, a lease incurs extra risk. This risk is managed by raising the cost of the lease versus a pure purchase. It the seller sets lease terms (including buyout) better than a purchase, they are inticing the buyer/lessee to go that route, and the agreement may not pass the IRS sniff test.

Tesla forces the lease to only be a lease. That is the safest route when passing along the credit.
 
Yes, and the business is the one who put in the lease buyout clause.


Which have been in those leases for years and years before the IRA existed.

So either they were never leases (which good luck with THAT legal argument) or they STILL are leases.


IRS has plenty of experience with leases outside of vehicles such as wider equipment and property in general. Even outside of leases, parties involved can call a transaction one thing, but IRS could look at intention, how things are structured, likelihood of something happening, etc. to treat it as something else, e.g., a sale.

Again though the structure of the lease is unchanged from years and years of previous pre-IRA leasing.

There is no change at all in lease structure from the leasing company here.

It's simply that customer behavior is causing them to use the existed-for-years buyout clause more often.


IRS might even start from reports like "EV LEASING | Expected to Rise Further in 2024" (Cox Automotive Industry Insights 2024 PDF page 25) where in 2023, EVs went from under 10% leases (-5% vs industry) to nearing 25% (+5% vs) to decide if they should put effort into investigating what percentage should actually be recharacterized as sales. Then again, perhaps these numbers show that the IRS shouldn't bother because clearly so many businesses are leasing EVs and must be doing the right thing and not worth their time?

It's possible the IRS might consider new guidance at some point--- but I don't think there's any way, at all they can retroactively say "Those 2023 leases suddenly weren't really leases-- despite using the exact same structure as previous leases going back years"

So nobody who did this in 2023-- or is doing it TODAY lacking any new rules from IRS, ought have any concerns... (indeed the person buying out the lease would never have cause for concern... it's the leasing company on the hook if IRS changes the rules)



As the laws are now, §30D incentivizes locally-made EVs while §45W incentivizes commercial usage of EVs, and both seem to align with accelerating the transition to sustainable energy with Tesla making use of both.

Exactly.

This isn't a "loophole", this is working as designed.



As a seller, a lease incurs extra risk. This risk is managed by raising the cost of the lease versus a pure purchase.

Sure. Likewise they include the buyout options-- where they STILL make more total than if they'd done a pure sale.


It the seller sets lease terms (including buyout) better than a purchase, they are inticing the buyer/lessee to go that route, and the agreement may not pass the IRS sniff test.

But the terms of the LEASE haven't changed.

It's not the leasing companies fault that an individual does not qualify for some purchase tax credit--- nor even their responsibility to check.

Heck someone without cash on hand for a purchase but who CAN afford lease payments will ALSO find a lease "better" than a purchase- but that doesn't mean it's magically not a lease.



Tesla forces the lease to only be a lease. That is the safest route when passing along the credit.

You keep saying this- but see my discussion above-- I do not believe IRS could announce "Naah leases with buyout clauses aren't leases" without negating years and years of leases from well before the IRA existed.

Nor do I believe every legacy finance company in the business would've taken on ANY risk of that happening if they thought it existed.

Certainly IRS could issue NEW guidance that'd apply to future leases around this stuff...then leasing companies might have to revise their terms--- but today they don't--- and either way it's 0.00% risk to buyers.
 
Which have been in those leases for years and years before the IRA existed
And the law changed in a way that the IRS might want to care now. Just like a burrito is a burrito that everybody calls a burrito can suddenly be treated as a sandwich for tax purposes when a state wants to ensure they're getting money. The fact that the IRS provides a Q&A related to leases recharacterized "as a sale for federal income tax purposes" indicates they are aware it's something they could enforce for what everyone would call a lease.
 
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And the law changed in a way that the IRS might want to care now. Just like a burrito is a burrito that everybody calls a burrito can suddenly be treated as a sandwich for tax purposes when a state wants to ensure they're getting money. The fact that the IRS provides a Q&A related to leases recharacterized "as a sale for federal income tax purposes" indicates they are aware it's something they could enforce for what everyone would call a lease.


I agree they might wish to care now- I just don't think they can actually, functionally, change the treatment of leases that haven't changed the lease terms at all without issuing new rules beyond the ones they have thusfar.

In fact in that Q&A they make clear they're NOT issuing any new guidance at all regarding if something is a sale or a lease.

IRS said:
based on longstanding tax principles, the determination whether a transaction constitutes a sale or a lease of a vehicle for tax purposes is a question of fact.

They then list common features of leases, based on past guidance and rulings that would indicate it's really a sale.

None of which, as already discussed, apply to these leases in question.


So again they'd need to EITHER:

Issue new guidance impacting FUTURE leases
or
Retroactively decide ALL car leases, going back years, where the customer exercised a buyout option, were really sales


Because "what is a lease vs a sale" is not changed at all by the IRA or their current rules or guidance around it.

That first one is certainly possible--- the second is... exceedingly unlikely.
 
Retroactively decide ALL car leases, going back years, where the customer exercised a buyout option, were really sales.
It's not that the buyout clause was exercised, it's that the lease was structured in such a way that it was fiscally on par with a straight sale.

In this discussion, the impact is only to the applicability of 45W credits, which have only existed since Jan 1 2023. Previous cases of leases that were sales would have already been delt with.

However, it is a thing that is covered in other business purchases:
Purchasing vs. Leasing
You can acquire the property under a purchase option for a price that is nominal in relation to the property's value at the time you can exercise the option or that is nominal in comparison to your total payments under the lease.
Subtracting the credit makes the price even better than nominal.

Here's the core issue as I see it: does the $7,500 credit reduce the fair market value of the vehicle at the end of the lease? It reduces the lessor's cost, but that's an independent matter. IMO, a lease that adjusts the residual/ buyout by ~$7,500 or the payments by ~$7,500 (total acquisition cost on par with a sale) is structuring itself as an installment purchase that exists to pass along the credit the lessee or car otherwise doesn't qualify for (exactly the scenario you originally called out).


More links:
A to B to C to D may be just A to D:
A walk through the step-transaction doctrine
Reclassification:
https://www.elfaonline.org/docs/def...s-and-service-contracts.pdf?sfvrsn=5ce0b80d_2
Real estate version:
Lease with a Purchase Option ... or Sale? It Matters to the IRS - ORBA
Lease Options: When Does the IRS Consider it a Sale?
 
It's not that the buyout clause was exercised, it's that the lease was structured in such a way that it was fiscally on par with a straight sale.

It's not though- there's fees and interest (though not MUCH interest if you buy out quickly- that being the point of doing it quickly)

You can dismiss them as being smaller than the $7500 saved- but that doesn't make it not a lease.... they are, again, the SAME fees as before the IRA existed.





In this discussion, the impact is only to the applicability of 45W credits, which have only existed since Jan 1 2023. Previous cases of leases that were sales would have already been delt with.

That's my point.

If they were NOT sales before 45W, they're still not sales now because 45W does not provide any mechanism to reclassify them.


However, it is a thing that is covered in other business purchases:
Purchasing vs. Leasing

The bit you're citing is

"You can acquire the property under a purchase option for a price that is nominal in relation to the property's value at the time you can exercise the option or that is nominal in comparison to your total payments under the lease."

Nominal means "far below the real value or cost."

The buyout of the lease is for exactly the real cost -- plus the leasing and buyout fee.

That's higher, not "far below"

The cost is based on what it cost the leasing company to acquire the car. Not what someone else might hypothetically have paid for it.


Subtracting the credit makes the price even better than nominal.


Here's the core issue as I see it: does the $7,500 credit reduce the fair market value of the vehicle at the end of the lease? It reduces the lessor's cost, but that's an independent matter.

It's not though.


You're still conflating the cost to the customer-- which is irrelevant to determining if it's a lease--- and the cost to the leasing company.

In your previously cited example the people who might have a problem with it "not being considered a lease" are the END BUYERS. NOT THE LEASING COMPANY.

That is not at all relevant here.

The ONLY party relevant is the leasing company- because they are the ones who got the credit.

And they're not offering a buyout for LESS THAN THEIR COST of the vehicle.

Anyway the rest of your links seem to have a similar confusion on your part-- they're all about the guy on the END of the lease and the IRS.... which is irrelevant here.



IMO, a lease that adjusts the residual/ buyout by ~$7,500 or the payments by ~$7,500 (total acquisition cost on par with a sale) is structuring itself as an installment purchase that exists to pass along the credit the lessee or car otherwise doesn't qualify for (exactly the scenario you originally called out).

The leasing company reduces the cap cost, not the buyout. If you never buy out the lease AT ALL you still benefit.

So suggesting lowering the cap cost makes it a sale is obviously wrong since it happens even when you don't buy the car at all



This is all on top of, and I know you dismiss this as appeal to authority but it's not "Well one authority says..."--- Literally EVERY car company/financing company, with their slew of accountants and lawyers, thinks you are wrong on this, and has conducted (at least) hundreds of millions of dollars of business on the basis of you being wrong about it.

Audi, BMW, Stellanis, Ford, Genesis, Hyundai, Jaguar, Kia, Lexus, Lucid, Mercedes-Benz, Mini, Nissan, Polestar, Porsche, Rivian, Subaru, Toyota, Volkswagen, and Volvo.

Every. Single. One. is giving $7500 off via leasing. And you're suggesting all of them will owe every penny of it back to the IRS based on what continues to be an IMHO not-quite-right readings of a couple of lines of an FAQ.
 
Tesla just dropped Model Y LR prices by $4K CAD in Canada to take advantage of a new $7,000 CAD rebate now offered in Quebec for EVs priced under $65K CDN.



Combined with the Federal rebate of $5K that's a total of $12K off on a Model Y. Now with a base price of $63,990 or about $53K in Quebec after rebates.

BTW, Provincial Sales tax in Quebec is 9.975% before GST, so on a $65K vehicle the new $7K rebate is just basically waving the sales tax, plus 500 bucks... :p

Even with this price drop, my April 2022 Model Y LR was still about $3K less than this new price. Plus, I got the White Interior which is no longer available in Canada because these cars come from SHG which only offers black interiors. The 7-seater only just became available.

So SP instantly dropped to the Options C/P 'breakpoint' @ $185 to start the pre-Mkt :p
 
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