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5100.16 transfer in bond


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Hello friends,

I am working on transferring barrels of whiskey.  On form 5100.16, it is asking for effective date of bond and amount.  My DSP registration states I am not required to carry a bond based on :

"I am not required to furnish a bond only if all of the following are true; I will withdraw spirits for deferred payment of tax under 27 CFR 19.235, I was liable for not more than $50,000 in distilled spirits taxes in the preceding calendar year, I reasonably expect to be liable for not more than $50,000 in such taxes during the current calendar year, and I have no operations or withdrawals involving spirits for industrial use."


So question 1:  Is a bond required to receive a transfer in bond?   Question 2: If no, how do I properly fill out form 5100.16


Thanks in advance!






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  • 2 weeks later...

Hi Coach,

I'm retired from TTB's NRC here in Cincinnati where all applications are processed. Question 1: You do not need a bond to receive spirits transferred in bond. Question 2: If you filed your original DSP application by paper, you'll have to mail a completed TTB F5100.16 to the NRC. The latest edition, 11/2016, is available at ttb.gov. If you filed your application using Permits Online (PONL) you will submit an amendment via PONL. It's pretty straightforward. If you have any issues or further questions, contact me at langdonguenther@gmail.com and/or 513-257-9378. A caveat: PONL filers will receive an approved TTB F5100.16 that has an edition date of 10/2009, instead of 11/2016. It's another PONL glitch that has not been fixed yet. This has caused some concerns and issues with DSP's that are shipping the spirits. Get your request in as soon as possible. Processing time on these requests at the NRC was recently 2-3 weeks. Hope this helps.













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