This post is intended to be a quick Public Service Announcement since we’ve observed an increase in this type of transaction. Both copackers and distillers are routinely running afoul of regulations surrounding Transfer in Bond of bottled/canned product, by sending and receiving canned product via Transfer in Bond. Unless the copacker and their distillery client…
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TTB regulations are stiff for the most part, but if you are a careful student, you can find some regulatory “freebies” that can save you significant amounts of time and money. Here, we’ll cover three of the most important ones. 1) You Don’t Have to Take Physical Inventory of Barrels This one’s a bit tricky because…
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At first glance, you might wonder why regulations distinguish between Voluntary Destruction and Losses. The key differences: In either case, you’re typically not taxed on the quantity lost/destroyed – but let’s dive in deeper. Voluntary Destruction Voluntary Destruction is covered in 27 CFR 19.459, which states: A proprietor may voluntarily destroy spirits […] or wines…
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A good buyer will provide capital for growth — a great one will work with you to ensure that both the business and its unique culture thrive.
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Are you working on a new formulation? Here’s a few common ‘gotchas’ to watch out for: Does your product really need a formula? – There are several “general use” formulas for Vodka, Brandy & Whiskey – Products adhering to a recognized Class & Type (e.g. Aquavit) do not require a formula submission – Check the…
All Distilled Spirits proprietors need to know about two substantial changes in in TTB Enforcement standing policy. 1. Change in Ownership Reporting If you have a change in ownership of your business, you must report that change to TTB via a Permit Amendment within 30 days. Reportable changes include: change of controlling interest, change of 10%+…
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The TTB is charged with two primary missions: protect revenue and protect consumer. Because of this focus, they are very concerned with alcohol content measurement in distilled spirits plants – an underproof product shortchanges the consumer, while an overproof product shortchanges the government its excise tax; enter proofing and gauging. Accordingly, 27 CFR has strict…
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Selecting the right equipment for your new DSP is a challenge. Even if you have the budget to purchase everything brand new, many of the items you need have long lead-times and require professional installation. Plus, everything you buy must work together. What is a new distillery to do? The best option is to seek…
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