A reader comments on this post
Am I the only one that is worried that the TTB will interpret this new regulation to allow only wines that were actually produced by the winery that removes the wine to be eligible for the new credits? The language specifically says "Produced and Removed". This is the same language that has been interpreted as disallowing wines that were transferred to warehouses and removed by the warehouse, when the winery that holds title didn't actually produce the wines inside the bottle, making most, if not all, wines removed by the warehouses ineligible for the credit. This will cause massive disruption in the existing system of wine distribution for small, medium and large wine companies. I for one am not advising any clients on what I think the tax implications will be for January 2018 until I see what the TTB has to say next week. Of course, we only have three weeks to sort this out before the first semi-monthly period ends on January 15th. I for one am very concerned.