TTB to release revised Report of Wine Premises Operations
January 25, 2018
By Olivia Leigh, Director of Alcoholic Beverage Licensing
Ever since Congress passed the Tax Cuts and Jobs Act, we and our customers have been waiting to hear from TTB on how they will implement the different provisions of the new law. TTB released initial guidance on how to report excise taxes two weeks ago, but that left several puzzle pieces missing. One of those key pieces of information is whether wineries should continue to use the 5120.17 Report of Wine Premises Operations (aka “702 report”) form in its current format. Using the existing 5120.17 form with incorrect alcohol by volume (ABV) ranges doesn’t appear to make sense when 5000.24 excise tax return totals will be calculated using the new 16% threshold.
Fortunately, the government shutdown ended just in time for TTB make the planned trip to the Unified Wine and Grape Symposium this week. We were able to chat in person and get clarification that TTB does indeed intend to update the 702 form with the new ABV ranges (not over 16 percent/over 16 to 21 percent), but the estimated timeframe is by mid-February. In other words, they hope to have this done before the Report of Wine Premises Operations is due on February 15th.
As always, we will continue to post relevant updates here as the changes evolve and interpretation of the laws becomes more solidified.