Nobody hopes for an audit, but like cold cloudy summers in San Francisco, they’re bound to happen. Ideally, if you’re selected for an audit by the Alcohol and Tobacco Tax and Trade Bureau (“TTB”), you will have already been following the federal requirements. To aid in compliance, last March the TTB issued a tutorial about the common issues found during TTB audits, which is available here. As the ramp up to harvest begins, this is a good resource to circle back with to ensure compliance. Within the tutorial the TTB listed the most common compliance issues by area, and within that by frequency of occurrence. Further, they provided helpful tips on how to avoid problems in those areas. The issues most frequently seen by the TTB’s Tax Audit Division are:
General record keeping;
Transfer in bond record;
Tax paid removal records; and
Inventory timing, records and signature;
Inventory losses and loss limits; and
Records of bottled or packed wine.
Reporting and Tax Payment:
Timely filing the Report of Wine Premises Operations and correctly completing the form;
Calculating and paying tax on wine;
Filing claims for wine or spirits lost or destroyed while in bond;
Tax payment and filing TTB F5000.24 Excise Tax Returns; and
Basic Permit, Registration and Bond:
Filing amended applications to report changes; and
Maintaining adequate bond coverage.
If you would like assistance with a TTB audit or help with TTB compliance matters, please feel free to contact the attorneys at Strike & Techel.
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