Motor Fuels Tax Minute, Episode 99: M-Registrations
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In this episode of Motor Fuels Tax Minute, our hosts discuss m-registrations and their requirements.
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Detailed Description of Weaver’s Motor Fuels Tax Minute, Episode 99
00:00:00
Kelly: Welcome to our Motor Fuels Tax Minute, where we talk all things motor fuels. Once again, Leanne and I are hanging out in Houston for this nice day today, and we are going to talk a little bit about M-registrations.
They are becoming a pretty hot topic. What are the requirements for those, Leanne?
00:00:17
Leanne: Yeah, so it’s a hot topic because the requirements have never actually changed, but the way the IRS has interpreted it or enforced those requirements has changed over the years.
When I first started in this industry, and I’m going to date myself, but back in 2006, almost 20 years ago, you could get an M-registration if you were blending fuel. So, if you were blending gasoline, blending diesel, blending biodiesel, anywhere in the distribution system, the IRS would issue an M-registration. Now, technically, some of that was incorrect.
The M-registration is actually for blending a taxable fuel below the rack. So, if you’re doing all your blending in an IRS terminal, then that technically doesn’t need an M-registration. It’s covered by the S-registration. If you are blending B-99, I’m going to say arguably you don’t need the M-registration. The diesel is taxable, but what you’re creating is not a taxable fuel.
Over the past couple of years, the IRS has really honed in on this, and we’re starting to see, I’ve talked before about canceling registrations, we’re starting to see some M-registrations be revoked for people that are not blending like an E85 type product in non-bulk storage.
So where does that get a little tricky? It gets a little tricky with that in-line blending. They come down two separate lines, they meet right at the end as it goes into a tank, like a truck tank, at the rack. So it’s going into this truck and it mostly gets mixed in there. So where is it actually blended?
If you’ve got a B-99, well, maybe we’re still arguing it’s not a taxable fuel, but if you’ve got an E85 and it’s mostly getting blended right as it comes out where the line comes together, mostly blended in the truck tank, is it blended below the rack? Do you need that M? That’s a big question that we’re seeing. We don’t necessarily have the answer and sometimes it depends on the agent.
So, if you’ve got an M-registration, just look out for those audits and think about if I’m only blending in tank, I probably don’t need it. If I’m blending below the rack, I do. If I’m blending at the rack, well, that’s a big maybe.
00:02:35
Kelly: Wow, that is a lot of good information. That is a huge issue I’m sure companies are running into. It’s hard when you have to rely on the agent to kind of tell you what you should be doing.
It’s also a great area where Weaver can always assist. It sounds very complicated, very technical. We have Leanne, she’s obviously knowledgeable in this area. So, if you have any questions about that or if you’re concerned about your current M-registration or just want some more information, feel free to reach out.
That was this week’s Motor Fuels Tax Minute. Thank you for joining us.
