That's an important point that I missed in my research, though it does seem like there are limitations? [1]
If the buyer's previous-year adjusted gross income is too high they still don't qualify, and if the buyer's purchase-year adjusted gross income is too high they can end up owing money to the IRS.
And dealers/sellers have to qualify and register but...
> Advance payments received by the registered dealer are not treated as a tax credit to the dealer and may exceed the dealer’s regular tax liability. Advance payments received by the registered dealer are not included in the gross income of the dealer.
That does read as a direct subsidy equivalent to a refundable tax credit straight from the general fund.
If the buyer's previous-year adjusted gross income is too high they still don't qualify, and if the buyer's purchase-year adjusted gross income is too high they can end up owing money to the IRS.
And dealers/sellers have to qualify and register but...
> Advance payments received by the registered dealer are not treated as a tax credit to the dealer and may exceed the dealer’s regular tax liability. Advance payments received by the registered dealer are not included in the gross income of the dealer.
That does read as a direct subsidy equivalent to a refundable tax credit straight from the general fund.
[1] https://www.irs.gov/newsroom/topic-h-frequently-asked-questi...