Easier TTB forms for small producers?

[grehorst]

email message received by Bill Owens...

I've gotten the green light to develop a recommended short form for the small distiller. Can you call me this week to provide input. I'm thinking under 10,000 pg's production per year as a top range. Also, I would appreciate input as to how many types of spirits to report. I do want to talk about disposition for non-beverage. If the Distiller wants to sell spirits for other than beverage, they probably will not qualify for a short filing?

DAVE BATEMAN

DISTILLED SPIRITS INDUSTRY ANALYST

202-302-3859

816-623-9405

FAX 816-623-9405

[DISTILLERnhas]

For what it's worth.

The amendment to the current law in Michigan has included a definition of a "small distiller" as a producer of less than 60,000 proof gallons per year.

Just FYI

[grehorst]

For what it's worth.

The amendment to the current law in Michigan has included a definition of a "small distiller" as a producer of less than 60,000 proof gallons per year.

Just FYI

I think that's a much more workable number.

[dgpoff]

I think that's a much more workable number.

Ditto!

[Fred Linneman]

I think easier forms are a great idea - Also agree with the higher proof gallon limits below

Fred

[grehorst]

I emailed Dave Bateman requesting that the upper limit for small producers be increased to 60,000P.G.- I suggest others also email or call him on this matter....

His email is dave.bateman@ttb.gov

[will]

The real question is "what's the cost in regulation that is saved by simplified reporting?" That has to be the TTB's internal view. Based on that, 75,000 pg is just over $1mm - probably a useful number.

Other way to arrive at a useful value: How many companies are regulated by the spirits group in the US? Graph them against their tax liability, biggest on the left. Draw a line to the right of the knee in the curve. How much spirit is that? I'm guessing it's around 500,000 pg. $6.75mm tax liability.

[delaware_phoenix]

I'm curious about exactly what you're looking at Guy as far as changed reporting. Is this for the tax returns, monthly production reports, quarterly inventory? All of the above?

I just got my Federal permit and am beginning to work with the various reporting mechanisms. So I don't have any experience with them at all.

[thomastew]

For us, the most beneficial item would be reporting quarterly vs. monthly. We received this benefit for our brewing operation a few years ago and it has been fantastic. The TTB allowed brewers making less that 60,000 bbls/year to qualify for the paperwork reduction. It has always appeared to me that the TTB is most concerned with collecting and being able to predict revenue. At the current level a 60,000bbl brewer might be expected to report around $105,000.00 ($7x15,000) of tax liability per quarter. A distiller with the same type of quarterly tax liability would be someone making around ~30,000pg /year ($420,000/$13.50). Of course, the brewer liability is based on the lower tax rate for small brewers. The same line of logic might drastically increase the distillers that qualify if a lower small distillers tax rate was created. With this thinking it may be wise to wait to see how far that piece of legislation goes.

Brent

Brent Ryan

Newport Distilling Company

Newport, RI