Tesla is near the 200k mark and has been holding back domestic sales so to hit it at the beginning of a quarter (i.e now).
Edit: Here is a link to the official explanation of the credit in glorious IRS legalese (https://www.irs.gov/irb/2009-48_IRB#NOT-2009-89).
Relevant quote from the IRS to this discussion:
"The new qualified plug-in electric drive motor vehicle credit phases out for a manufacturer’s vehicles over the one-year period beginning with the second calendar quarter after the calendar quarter in which at least 200,000 qualifying vehicles manufactured by that manufacturer have been sold for use in the United States (determined on a cumulative basis for sales after December 31, 2009) (“phase-out period”). Qualifying vehicles manufactured by that manufacturer are eligible for 50 percent of the credit if acquired in the first two quarters of the phase-out period and 25 percent of the credit if acquired in the third or fourth quarter of the phase-out period."