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"The Many Faces of Custom Crush"

Caraker Law Firm, P.C. Custom Crush/Production vs. Alternating Proprietorship Licensing - Compliance - Guidelines. "The Many Faces of Custom Crush". Small Firm Located in Central Missouri Areas of practice: TTB, IRS and State Departments of Revenue and ABCs.

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"The Many Faces of Custom Crush"

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  1. Caraker Law Firm, P.C. Custom Crush/Production vs. Alternating Proprietorship Licensing - Compliance - Guidelines "The Many Faces of Custom Crush"

  2. Small Firm Located in Central Missouri Areas of practice: TTB, IRS and State Departments of Revenue and ABCs Who is Caraker Law Firm, P.C.?

  3. Enrolled Agent Audit/Examination Specialist Primary Winery Contact Who is April L. Roof?

  4. Alcohol and Tobacco Tax and Trade Bureau (TTB) Internal Revenue Service State Departments of Revenue and Alcohol Beverage Control (as allowed by state law) What does Caraker Law Firm, P.C. do?

  5. Relevant Terms Difference between Custom Crush and Alternating Proprietorship “Pros” vs. “Cons” TTB Concerns Policy/Expectations Overview

  6. Bonded Wine Premises Bonded Winery Bonded Wine Cellar Relevant Terms

  7. Bonded Wine Premises

  8. Bonded Winery

  9. Bonded Wine Cellar

  10. “Client” - provides raw material - possibly instructions “Producer” - provides facility, staff, sometimes storage - responsible for virtually all record keeping Custom Crush/Producer

  11. Custom Crush/Producer

  12. Custom Crush/Producer

  13. Custom Crush/Producer

  14. Custom Crush/Producer

  15. “Client” may need a Wholesaler's Permit “Client” may also need to pay a Special Occupational Tax ($500/$250) Custom Crush/Producer

  16. “Host” - Bonded Winery, Premises, Equipment “Tenant” - Bonded Winery Alternating Proprietorship

  17. Alternating Proprietorship

  18. Alternating Proprietorship

  19. Alternating Proprietorship

  20. Alternating Proprietorship

  21. BOTH must be a Bonded Winery BOTH responsible for own recordkeeping APs MUST have TTB-approved plan Alternating Proprietorship

  22. Small Domestic Producers Credit (SDPC) Wholesale vs. Retail Marketing & Promotional Privileges Control “Pros” vs. “Cons”

  23. Need for Permit SDPC Ability to keep inventories separate TTB Concerns

  24. AP Agreements and Qualification Suitability of Premises Staff Access to Premises Policy / Expectations

  25. Changing Terms of AP Agreement SDPC Permanent Premises Alternation for Less than One (1) Day Policy / Expectations, cont.

  26. Every state is different (of course!) Most rely on Federal documents for licensure Some have more stringent requirements What about the State?

  27. Custom Crush is for some. Alternating Proprietorship is for some. Establishing an independent, free-standing Winery is for some. Conclusion

  28. www.carakerlawfirm.com april@carakerlawfirm.com (800) 470-0173 Make sure to enter our drawing to win 1 of 5 TTB set-up packages OR an e-reader. Booth 1011 Caraker Law Firm, P.C.

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