Shilling

If you are denaturing and then selling you would need to amend your permit to include industrial alcohol and then submit and receive formula approval for the particular denaturing process(es) you are using. Denatured is not subject to FET. If you are selling undenatured and untaxed the purchaser will need an industrial use permit and meet the requirements for tax-free alcohol use.

Well, the short answer is no, but unless you are importing the reduction is really pretty straightforward. 

What specifically are you in need of?

You *can* participate in either the WSET Class or the Architecture/Design Class without registering for the entire conference!

$1850-3200

20 hours ago, indyspirits said:

Is it not clear from comments in this topic?  I know how much you charge vendors and now attendees so I find it difficult to believe ACSA is losing money.

The only thing that is clear is the desire for a trade show only pass, which is a really good question and one that I will ask about. Other than that, the only thing I'm getting is that the 600 is too much for not enough return. I'm hoping to be able to take some good solid feedback that I can share, so I guess my questions is this: Is 600 too high regardless of the content, or is it just not that right content for the price? And if that's the case, can I get some specific examples of what would make it worthwhile?  Incidentally, the booths for the trade show have been sold out for a while and there is significant waitlist.

It costs a lot of money to put on a conference. What's missing that you'd like to see?

The language proposed by TTB would have allowed the in bond transfer of bottles only "between bonded premises belonging to the same distiller", so I think it was really more about the distance restrictions.

Either way, I agree with you 100% on waiting for detailed TTB guidance on this section.

I'll happily pass all this along.

Although I agree with you 100% on waiting for TTB additional and detailed guidance, I'm curious as to your interpretation on the tax rate. The rate of $2.70 will apply at removal and if bottles have been TIB'd they have not been removed...I don't see where production or processing comes into play.

EDIT: After re-reading your post, I see where you're coming from.

I believe the *intent* was to allow a DSP to move cased goods from their bonded production area to an offisite bonded warehouse for storage prior to distribution, etc, and that it was never intended to allow transfer between two separate DSP's but Congress doesn't always understand the nuances of what they are doing. All that being said, I do believe the 2.70 rate will apply based on the DSP finally removing the product regardless of the production or processing question.

Make sure your distillate and water are at the same temp when you proof down.

If you are considering lowering your prices, you might also consider that you don't really set your prices (except for onsite sales and a few very minor cases). Prices are set by distributors, retailers and state governments. Most people, it seems, will be adding staff and/or production capacity.

On 12/21/2017 at 5:56 PM, 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.  

The 100,000 pg figure was based loosely on the corresponding volume difference between rates for small and large brewers, and the rate of $2.70 was based loosely on the difference in rates paid for the small and large brewers.

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.

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.

The new rate of $2.70 applies to any product removed from bond on or after January 1st. Side note: if you are you a compliance service like Whiskey Systems, Distillery Solutions, etc. you should check with them to make sure the software is updated - if not you may have to report and pay 'old school' for the first few periods.