Advocacy Comments on TTB’s Proposed and Temporary Rules on Refund Procedures for Excise Taxes on Alcohol Imports

On September 23, 2022, the Alcohol and Tobacco Tax and Trade Bureau (TTB) published temporary and proposed rules implementing amendments to the Craft Beverage Modernization Act provisions of the Internal Revenue Code (Code). The proposed and temporary rules reflect amendments to the Code found in the Taxpayer Certainty and Disaster Tax Relief Act of 2020. The rules establish refund procedures that will allow importers to take advantage of tax benefits applicable to imported alcohol products on a quarterly basis. Prior to the statutory amendments, importers were allowed to elect Craft Beverage Modernization Act tax credits when alcohol products entered the United States.

On November 18, 2022, the Office of Advocacy filed a comment letter encouraging TTB to publish either a supplemental Regulatory Flexibility Act assessment or an Initial Regulatory Flexibility Analysis, allowing additional time for public comment.

For more, read the public comment letter and fact sheet, which highlights Advocacy’s concerns and recommendations.