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We spent five figures for a lobbyist on this one. This is huge.

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9 minutes ago, Rum said:

This is huge.

That's the understatement of a decade. It will truly make a huge difference for us. 

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14 minutes ago, Rum said:

We spent five figures for a lobbyist on this one. This is huge.

Money well spent it seems.

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A couple points for those who haven't been following this.

1. It's not official yet.

2. The FET reduction is only for 2018 and 2019. After that it reverts to the previous rate.

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It has both positive and negative connotations. On the positive side it will act as a sort of "scale equalizer" for small distillers to offset some of the price pressure that large distillers can bring to bear due to their economy of scale production techniques and capacity. 

On the negative side it may very well cause a flood on the market of new Fakeilleries (big and small) who will all be MGP "ish"  type drones, dumping Fake Craft on the market at even lower prices than before, therein causing even greater harm to actual Craft Distillers.

The big money behind mass produced alcohol didn't do this out of the goodness of their hearts. They pushed it because it fits the current Fake Craft model.

Well take it for now, but be careful what you wish for. 

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I am a little surprised how high they set the limit for the lower tax.  100,000 proof gallons is not really craft IMHO.  Probably could have been half or 1/3 that volume.    Just over $1,000,000 per year tax savings for the big guys.  

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Sliding scale up to 100,000 PG is still my strong preference.  And I reject the idea that a sliding scale is "too complicated" for anyone who has the capabilities to start and operate a DSP.   I would hope that we all do everything we can to make sure small 1-person distilleries can start up and survive.  Our "craft" market's appeal depends on a viable industry that offers variety and offers radical little distilleries making radical little products.   I would prefer to not see a "craft" market full of distilleries skirting the 100,000 gal. line.  Those distilleries would likely appear and function very similarly to each other and likely make our industry too boring to appeal to the next generation.........Right?

....Not to look a gift horse in the mouth, but we can still improve upon this idea of lower excise taxes.

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4 hours ago, bluefish_dist said:

I am a little surprised how high they set the limit for the lower tax.  100,000 proof gallons is not really craft IMHO.  Probably could have been half or 1/3 that volume.    Just over $1,000,000 per year tax savings for the big guys.  

How many distillers making a few thousand proof gallons could afford the lobbiests needed to pass something like this in the Federal level?

 

Answer: none. That is why the level is where it is.

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REJOICE, as it is far better than a sharp stick in the eye!

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I've never looked at pre-paying excise taxes, but isn't it plausible that at the end of 2019, we all plan to pay excise tax on all spirits in inventory?  This would be a Dunbar question, but if you would have the capacity to pay excise for 100,000pg before it expires, you do it.

 

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1 hour ago, Silk City Distillers said:

I've never looked at pre-paying excise taxes, but isn't it plausible that at the end of 2019, we all plan to pay excise tax on all spirits in inventory?  This would be a Dunbar question, but if you would have the capacity to pay excise for 100,000pg before it expires, you do it.

 

Paging Mr Dunbar, Mr David Dunbar, please come to the conversation.   But seriously if you could do this, it would be a great idea and stretch this out.  Although i think they will just extend this at the end of two years.  Seems like once they give tax breaks its hard to take them away. 

 

 

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2 hours ago, whiskeytango said:

But seriously if you could do this, it would be a great idea and stretch this out.

As Joe Dehner said in another thread on this topic, just move all of your product out of your bonded facility into a non-bonded storage area at the end of 2019. 

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29 minutes ago, Huffy2k said:

As Joe Dehner said in another thread on this topic, just move all of your product out of your bonded facility into a non-bonded storage area at the end of 2019. 

I typically move product out of bond the day its bottled so that would not help me, but the idea of making a year or mores worth of gin/vodka in advance and moving that out prior to 2020 is interesting.  This strategy would really only work for distilleries that have access to capital and easy storage.

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19 hours ago, Jedd Haas said:

A couple points for those who haven't been following this.

1. It's not official yet.

2. The FET reduction is only for 2018 and 2019. After that it reverts to the previous rate.

1. It's official. President signed it this AM. 

2. I have no doubt that those who lobbied and pushed for this (brewing industry, wine industry, distilling industry) will continue to do so to make it permanent. Politicians don't often let things expire, and this reduction was very popular with both parties.   

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It was only done for two years so that it's revenue impact would be smaller. Had to stay under the 1.5 trillion number to keep it to a simple majority vote. The goal is to come back and make it permanent before the two years are up. No guarantees that will happen though.

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First, let me say stupid things - for which I don't need permission, because there is no stupid filter that will stop me, as I soon may demonstrate - then get out that grain of salt, and I'll comment.  But I ask in advance for forgiveness of things that will be proven wrong. 

There are a number of issues being discussed here that deserve comment.  Congress has thrown everyone who collects taxes, or advices on taxes, or has accounting software in place, a knuckleball, in the form of the  January 1 implementation date.  I can’t call it a curveball.  A curveball breaks, but it is a curve.  It follows the regular rules of motion, just as writing law, for good reason, is supposed to follow the regular order regular this act did not.  A mathematician can create an equation to describe a curve ball's motion and a batter’s brain can adjust the swing, at the lightning speed of a Google search, to make contact.  A knuckleball, on the other hand, is chaotically unpredictable.  There is no equation that can predict its motion.  this is a knuckleball, if for no other reason than we don't know what we don't know and aren't likely to know soon   what itis we don't know, let alone the unanticipated consequences that exist even with the due deliberation this Act lacks.  Add to the "rightnow" implementation date, the temporary nature of the decrease in the excise tax on spirits.  When will people have it figured out?  Not yet, that is certain.  

Today TTB writes in today's newsletter, "Congress has passed the Tax Cuts and Jobs Act of 2017, which makes extensive changes to the Internal Revenue Code of 1986, including provisions related to alcohol that are administered by TTB. The Tax Cuts and Jobs Act will become law when the President signs it. We are currently assessing the impact of these changes on TTB forms, regulations, and systems and will issue guidance and information in the coming weeks. Please visit our webpage for updates."

Forms, regulations, and systems, with no time to consider the changes that are needed now, not later, in all of them.  TTB's advice to follow the announcements it will be making on its webpage is sound.  Giving everyone six months or more to to figure things out would have been sound too.  But that did not happen. 

Accepting that this is a knuckleball - I'm not passing judgement on its merits, I'm talking about trying to take a swing that makes sound contact with the provisions - let's take a look at what I've been told the new provisions say.  "What I've beenb told" is code words for "I have not read the Act and so am relying on what others say,  just like most of those who voted on it.

Let's start with the temporary nature of the cut.  From the link adamOVD provided:

       “However, the tax breaks for the spirits industry will also expire in two years unless Congress acts to extend them or make them permanent in the future. The two-year period was set in order to  make the estimated overall $1.5 trillion cost of the package work within Senate rules and allow it to pass with a simple majority vote instead of requiring support from 60 Senators to end debate and move to a final vote. Gorman indicated that the industry’s lobbyists will continue to push Congress to make the changes permanent.”

From what I read, the $1.5 trillion is a pipedream.  Yes , statistics, liars, and damn liars all inhabit the same den, but the national debt tripled after Reagan's tax cuts.   That is not a politically motivated statement.  I am saying, I can't put much faith in ideologically driven prognostications of greatly increased revenues offsetting the decreases in rates.   Answers float like a butterfly, but can sting like a bee. The changes would have been better as a standalone amendment granting a permanent tax cut ; one that was not tied to artificial and perhaps unjustified assumptions that were needed to sneak it in under senatorial rules. 

As others have said, it probably is the kind of cut that congress is likely to extend.  But if the deficit hawks start circling, and the choice comes down to cuts in Medicaid and Social Security that will cause congressmen real problems with their constituency, even in heavily gerrymandered districts, who knows what congress may do?  "Likely to extend" and "unlikely to repeal" are different.  Think automatic renewal of subscriptions.  You can't rule out non action.  It is often an easy course. 

Next,  the thread contains a reference to moving everything into non bonded storage if the reduced rate expires.  The easy answer is, "If the sun does set on the reduction, which I think is doubtful, then a friendly banker would be a good friend to have, because the cost of borrowing the money needed to prepay the taxes would probably be a hell of a lot cheaper than paying them at the increased rate, but …."  But moving "everything" will not work.  Let's go there next.

Huffy2k posts - "Joe Dehner said in another thread on this topic, just move all of your product out of your bonded facility into a non-bonded storage area at the end of 2019." But moving all of the product into a non-bonded storage area will not work.  For spirits that you can reasonably anticipate soon selling, and which you could bottle and withdraw taxpaid before the sunset, prepayment makes sense.  The loan would be short-term.  But, because there are no  provisions under which you can bottle taxpaid spirits,   you could not prepay the taxes on anything not removed from bond, in a bottle, your newly rented non bonded warehouse, at the time the sunsets.  What can you do with barrels of taxpaid spirits?  That is a serious and rhetorical question.  There are provisions for qualifying to bottle taxpaid wine,  but similar provisions do not exist for spirits.  That would require changes to the law, not just regulation.  I think such changes are unlikely.  Do I need to say that impossible is probably a better guess?  

The "remove them from bond strategy" would then require that you hire an actuary and determine where the savings/sales curves intersect and take a flier on bottling x-years., worth of anticipated sales of spirits that don't have to age and removing them in anticipation of the sales you project.   Aged spirits would require a completely different calculation.  If you held a two year old spirit in a bottle for two additional years before you sell it, how much more would it have been worth if you kept it in the barrel for two years and then bottled it, paying the higher tax rate?  Plus, you might have to grant the bank, that is  extending the additional funds need to bloat your inventory, a security interest in the extra spirits you produce to get the x-year's supply into the bottle. If you have existing loans, the existing lenders are likely to have default first position on any spirits you produce, in addition to everything else you own, so the new lender might be, let's say, a little reluctant to bet on your ability to sell the product fast enough to repay the loan.   

Good luck with those sorts of calculations.

Next,  Roger posts, "On the negative side it may very well cause a flood on the market of new Fakeilleries (big and small) who will all be MGP "ish"  type drones, dumping Fake Craft on the market at even lower prices than before, therein causing even greater harm to actual Craft Distillers." 

Here, things really complicated.  The first rule  is easy to anticipate.  It will follow the EFT rules.  All of a company's locations will be lumped together to determine if, and when, they exceed the 100,000 ceiling.  The second set of rules will bend your minds,  because TTB is going to write rules that prevent a large distiller from creating a number of small distillers, or acquiring an interest in existing smaller distillers, from  allocating production between the locations, in an attempt to multiply the number of 100,000 proof  gallon thresholders, as a way of avoiding taxes.   Welcome to controlled groups.  The IRS and TTB have both been all over this in the past and because of the possible consequences of TTB adopting an awkward position, for the IRS, in other areas, TTB has always clung closely to the IRS's lead.

Whatever TTB does,m the rules are going to require that any distiller that is part of a controlled group aggregate its removals with the removals from all locations which are a part of the same controlled group.  I can guarantee that, because it is a principal built into the tax code for all sorts of taxes, including beer and wine excuse taxes, which both have reduced rates for small producers.  TTB will write rules that lump, for tax purposes, the  members of controlled groups, as defined in those rules, into a single entity, the controlled group.  Look at the provisions for wineries (Sec. 25.152) to see what the entails.  I'd quote the definition of controlled group found there, but it would send you to Philadelphia in search of a lawyer.  I know, I've been down that road with a client in the past.

TTB  also must address the difference between contact bottling and alteration of proprietors, as it has done already with breweries and wineries.   I've been on both sides of that issue and I assure you getting the wrong legal advice on how to structure alternation can be a very expensive experience.  Note that the word "very" occurs once and only once in this long discussion.   Very means very.  So TTB will have to provide some rules that prevent contract bottling under the guise of alternating proprietors.  Again, look to the wine and beer provisions - you will find them in industry circulares available on TTB's website - for an idea of how that is going to go.  I'll add this, it is possible that you could see large distillers taking  positions in craft distilleries, but I think the impetus to gobble both shelf space and distributor attention drives such scenarios more than the reduced rate ever will.  That sort of competition  is a reality with which you all must live, with or without the reduced rate legislation.  Further, I think those limitations are likely to slap a lid on growth, no matter how much capital is available from the reduced taxes you will be paying.  It is one thing to be able to produce 5,000 cases a year; it is another thing to be able to sell them.  

Brentondouglas comments on a sliding scale.  Now that the law is passed, that will not happen, but it is certainly manageable if it does  - see wine law and regulation -  and would have returned a more immediate benefit to the smaller producers, since the larger producers would have had to set a price point based on higher mean excise tax rate.  

Finally, and then I will shut up, the provision that allows removal of bottled spirits to another bonded premises is going to allow some "downstreaming"  of taxes.  That will be less possible in bailment states, and the cost of the distribution system might well dvour any savings made by the delay of taxation.  But the in bond transfer of bottled spirits will facilitate bonded warehouses to which bottled spirits are shipped for consolidation with others' products for shipments to more distant markets.  Again, this is going to lead to additional regulation, since the consolidator who pays the tax is going to have to justify the rate paid.  The consolidator is going to be on the hook if a distillery withdraws from two or more different locations and doesn't bother to tell the consolidator that the aggregate amount removed has exceeded the 100,000 ceiling.

There is a provision in the law and regulation (Sec. 19.56), that provides, "As a general rule, if a person intends to establish a bonded warehouse, other than one established on the bonded premises of a distilled spirits plant qualified for the production of spirits or contiguous to such premises, the proposed warehouse must have a minimum capacity of 250,000 wine gallons of bulk spirits and the need for such a warehouse must be clearly shown. TTB may consider an application to establish a bonded warehouse with less capacity provided a need is clearly shown."  TTB regularly approves such applications, and I generally advise clients not to worry about it, just apply for discontinuous premises.  But a consolidation warehouse is going to raise different issues.  TTB may not be willing to waive, so willingly, the 250,000 requirement.  

I'm sure there will be more to discuss.  This is just a start.  

 

 

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This tax change also affects your bond requirements. No bond required if you're paying less than $50,000 in alcohol tax.  So at the new rate that equals about 811 cases monthly of 80-proof spirit.

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There are parallel discussion going on.  On the other thread someone has posted the section of the law that applies to controlled groups.  So, fools rush in where ....

Here is the section on controlled groups 

‘‘(2) CONTROLLED GROUPS.—

‘‘(A) IN GENERAL.—In the case of a controlled group, the proof gallon quantities specified under subparagraphs (A) and (B) of paragraph (1) shall be applied to such group and apportioned among the members of such group in such manner as the Secretary or their delegate shall by regulations prescribe.

[This is standard - for beer, the brewer has to file a notice (Sec, 25.167)  which includes, among other things, "If the brewer operates more than one brewery, a statement of the locations of all the breweries and a statement of how the 60,000 barrel limitation for the reduced rate of tax will be apportioned among the breweries. If the brewer is a member of a controlled group of brewers, a statement of the names and locations of all other brewers in the group and a statement of how the 60,000 barrels limitation will be apportioned among the brewers in the group."  For beer, that is, it is flexible and up to the taxpayer.]
 

‘‘(B) DEFINITION.—For purposes of subparagraph (A), the term ‘controlled group’ shall have the meaning given such term by subsection (a) of section 1563, except that ‘more than 50 percent’ shall be substituted for ‘at least 80 percent’ each place it appears in such sub section. [

Here is where the Philadelphia lawyer comes into play,.    It appears that this section 1563 was not amended, so the old language remains.  The section defines three types of controlled groups,  parent-subsidiary, brother-sister, and combination.  Here is how it defines a parent-subsidiary controlled group, but keep in mind that where that section says 80%, we substitute 50%.  

_____________________________

(1)Parent-subsidiary controlled group - One or more chains of corporations connected through stock ownership with a common parent corporation if—

(A) stock possessing at least 80 percent of the total combined voting power of all classes of stock entitled to vote or at least 80 percent of the total value of shares of all classes of stock of each of the corporations, except the common parent corporation, is owned (within the meaning of subsection (d)(1)) by one or more of the other corporations; and
(B)
the common parent corporation owns (within the meaning of subsection (d)(1)) stock possessing at least 80 percent of the total combined voting power of all classes of stock entitled to vote or at least 80 percent of the total value of shares of all classes of stock of at least one of the other corporations, excluding, in computing such voting power or value, stock owned directly by such other corporations.
____________________________
The lesson here is don't even think about trying to understand it unless you must.  I'll spare you the other definitions and a trip into subsection(d)(1) etc ....

‘‘(C) RULES FOR NON-CORPORATIONS.—Under regulations prescribed by the Secretary, principles similar to the principles of subparagraphs (A) and (B) shall be applied to a group under common control where one or more of the persons is not a corporation.

Most of you are LLC's.  This says that the rules apply to you too.  Again, don't go here unless you must and most importantly:

Do not follow the advice of any who is not an attorney familiar with tax law AND controlled groups.  It is just too damned hard to follow.  Errors can be expensive.  

 

 

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46 minutes ago, daveflintstone said:

This tax change also affects your bond requirements. No bond required if you're paying less than $50,000 in alcohol tax.  So at the new rate that equals about 811 cases monthly of 80-proof spirit.

Yes, the quantities are correct.  But, remember, to qualify not to have a bond, you must pay some tax.  If you pay nothing, you have to have a bond.  Don't blame TTB for that.  It is how congress wrote the law :_).  

 

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5a3e6931d9d1c_ScreenShot2017-12-23at8_32_01AM.thumb.png.0061521b0f49940a00fb03b933c8c6d7.png

??? really .... I said finished bottled spirits, and yes it would work.

Another person said get a lawyer, I 100% agree.

Don't take any advice off these forums with out checking with proper people.

Take care:

 

 

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2 hours ago, Dehner Distillery said:

?? really .... I said finished bottled spirits, and yes it would work.

Another person said get a lawyer, I 100% agree.

Don't take any advice off these forums with out checking with proper people.

Take care:

Thanks Joe - I think we are all bound to misread/interpret some of what others say here.  Two things:

On the Need to Consult an Attorney

 I'm not advocating getting a lawyer, or a consultant :-), where the law and regulation are  easily understood.  But, when visions of legally avoiding a tax begin to dance in one's head after receiving what is touted as a universal Christmas gift of tax reform, remember that the government writes rules that are dizzyingly complex to plug any clever loopholes one thinks  one might be able to find in those rules.  

Big players with big money attorneys already have tried all the angles around controlled group legislation that might pop up in your dreams.   That is why the amendment that provides for a reduced tax rate includes controlled group provisions and references an already existing  section of the Internal Revenue Code that was devised, over time and from experience, to plug  any loopholes,  of which persons, with acronyms like MBA after their names, have tried to take advantage.  I  wrote what I did to say whoa, don't  go to fast.   For most of the people using this forum, controlled groups will never be an issue. 

On Transfers of Bottled Spirits in Bond

The provision allowing transfers of bottled spirits in bond is illustrative of the task that TTB faces.  Those familiar with the structure of the regulations know that they contain rules that describe what must, must not and may, but need be done.  When I teach it, I say it's like driving, you must have a license; you must not speed;  and you may, but need not, make a left hand turn at the next corner, but,  if you do make that turn, you must do it from the proper land and only after the proper signal. 

Transfers of bottled spirits in bond are an example of a "may rule ."   Therefore, TTB makes rules that describe what you must do if you make such transfers.  Part 19 contains sections that give the rules and sections that describe the records that are required.  TTB now faces the task of making rules for the transfer of bottled spirits and the records which persons who make such transfers must keep.  So, they must go through the regulations in a rigorous way - I'd say with the proverbial fine-toothed comb - to find all provisions that must be amended to establish the rules and recordkeeping requirements to accommodate the transfer of bottled spirits.  That will take awhile.  

Here are the sort of questions they will have to ask. 

  • Since it is a transfer in bond, does the language of the bond form need to be changed?  Yes, most of you will no longer need a bond, so that  will be moot in your cases, but TTB still must answer it because if some of your dreams come true, you will someday need a bond. 
  • Does the language of the Application to transfer spirits in bond need to be changed?
  • What changes must be made to the rules covering making the shipment?  For example, do they want to require that  the transfer record include the serial numbers of the cases transferred?  
  • What changes must be made to the rules imposed o the person receiving the shipment? For example, do they want to include specific provisions that apply to the discovery and reporting of in-transit breakage?
  • What changes must be made to the rules for claims on spirits that are lost due to in-transit breakage?
  • How should the receiving DSP record and report shortages that they discover at the time of receipt?  Remember, the spirits travel in the bond of the consignee, which means the consignee is responsible for the taxes.  Remember, also, that TTB takes a position that any shortages in bottled spirits held in the processing account are taxable.  But what happens in the case of a dispute, over the number of cases in the shipment,  between the shipping DSP and the receiving DSP?
  • What rules should cover the security (seals, locks, etc) required for shipments of bottle spirits?
  • Into which account would you receive bottled spirits?  Should TTB now make provisions to allow storage of bottled spirits in the storage account?  Remember, a person may not establish a DSP qualified only as a processor, so unless changes are made, a person could not establish a warehouse for the  storage of packaged goods only.  Can TTB changes those rules, or are they set in law.  

That is a list of questions that I've generated as I write, off the top of my head.  Some may not be a problem, others will be.  And TTB has until when to decide what it must do, what it may want to do, and what it is going to require?    

And as I type this, other questions occur. For example, "How do the label approval requirements fit into this new scheme?" would seem to be a major one.  Just for kicks, I'll quote one potentially problematic regulation;

5.55   Certificates of label approval.

(a) Requirement. Distilled spirits shall not be bottled or removed from a plant, except as provided in paragraph (b) of this section, unless the proprietor possesses a certificate of label approval, TTB Form 5100.31, covering the labels on the bottle, issued by the appropriate TTB officer pursuant to application on such form. A

 

It seems like some sort of amendment probably is in order.  Perhaps a statement to the effect, for purposes of Sec. 5.55, a distilled spirits plant that has received bottled spirits, in bond, must possess a copy of the COLA issued to the bottler, covering the labels on the bottled spirits in has received in bond, before it can remove the spirits form its plant, in bond, or withdraw them on payment of tax.

Sigh.

And how do you assign responsibility for the tax liability on overfilled and/or overproofed product withdrawn on determination of tax by someone other than the bottler.  As the King of Siam said to Anna, "Etcetera, etcetera, etcetera."

Now, I for one, am going to sit back and wait for TTB to answer those sorts of questions.  You guys can decide on the proper business strategy and the necessary tactics after TTB has done its thing.

 

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On 12/21/2017 at 4:26 PM, Roger said:

The big money behind mass produced alcohol didn't do this out of the goodness of their hearts. They pushed it because it fits the current Fake Craft model.

Well take it for now, but be careful what you wish for. 

I am bit late to the party on this thread, but I'd like to respond to a few things starting with this one. The big money behind mass produced alcohol did not do this at all. This reduction, loosely designed to mirror the already existing excise tax reduction for small beer and wine producers was born right here on the ADI forums, developed, submitted, and passed by small distillers from all over the country. While DISCUS was a part of the effort, they became involved only after we had it tee'd up.

As for the comment about fake distilleries flooding the market? I understand that concern but I think it's minor. For one, the cost of setting up system and the accompanying logistics would likely cost far more than the maximum ~$1mil savings per company/controlled group. That 'Fake Craft' model works on consumers (sadly) but it doesn't work so easily on the tax collector.

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On 12/23/2017 at 11:49 AM, dhdunbar said:

Now, I for one, am going to sit back and wait for TTB to answer those sorts of questions. 

The Bottled Spirits in Bond was most likely intended to give one distillery the ability to move product to another bonded location under its own DSP for storage. As it was written and passed, it looks like it now inadvertently allows the one DSP to transfer to a different DSP, which is where all the complexities raised above will set in. 

Although the reduced excise tax rate is effective for any product removed on or after Jan 1, I would most definitely wait for TTB guidance before messing around with TIB bottles.

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