The TTB has issued Industry Circular 2020-2 which postpones the payment of taxes due to the impact that COVID-19 is having on alcohol beverage industry members nationwide. TTB’s Acting Administrator has determined that (1) any person with a due date for submitting a Federal excise tax payment, return, operational report, or claim on wine, beer, distilled spirits, tobacco products, cigarette papers and tubes, firearms, and ammunition to TTB and (2) any person with a due date for submitting export documentation to TTB, in the period March 1, 2020, through July 1, 2020, is affected by COVID-19 for purposes of the relief described in this Industry Circular. To assist these businesses during this period, the TTB is postponing several filing and payment due dates for 90-days where the original due date falls on or after March 1, 2020, through July 1, 2020. Specifically, the TTB is: Postponing tax payment due dates for wine, beer, distilled spirits, tobacco products, cigarette papers and tubes, firearms, and ammunition excise taxes. Postponing filing due dates for excise tax returns. Postponing filing due dates for submission of operational reports. Postponing filing due dates for claims for credit or refund by producers. Postponing filing due dates for claims by manufacturers of nonbeverage products. Postponing due dates for submission of export documentation. Considering emergency variations from regulatory requirements for affected businesses on a case-by-case basis. Reviewing requests for relief from penalties based on reasonable cause. The TTB will re-evaluate the terms of this immediate relief if circumstances warrant. See…

Malkin Law’s contribution to the latest edition of Craft Spirits Magazine: “Ensuring Compliance With Third Parties” Some legal dos and don’ts when using third parties to promote your alcohol beverage brand. https://issuu.com/americancraftspirits/docs/craft_spirits_february_2020/60?fbclid=IwAR06yk7yT2Wni33LDy6Hoc84c-e-QVz_AU9XjOIfCQZIdyaSUNUS-ftPykQ —

See below from ASCSA, just remember to follow FDA rules and regs: American Craft Spirits Association GUIDANCE FOR DSP PRODUCTION OF HAND SANITIZER AND SANITARY SPRAY Craft distilleries around the country are stepping in to help alleviate our national shortage of sanitizing solutions. Two products in particular are in high demand: 60% ABV hand sanitizer and 70% ABV sanitary spray for surface disinfection. ACSA is working closely with TTB and FDA to ensure DSPs have the appropriate regulatory guidance and other information needed to ensure proper production and distribution guidelines are followed, as well as standards for safety and efficacy. TTB Just released from TTB, March 18, 2020 at 6:00p.m. This special edition contains guidance for DSPs and Industrial Alcohol User permittees on producing ethanol-based hand sanitizers. Due to the Coronavirus 2019 (COVID-19) pandemic, the Acting Administrator of the Alcohol and Tobacco Tax and Trade Bureau (TTB) has found that it is necessary or desirable to waive provisions of internal revenue law with regard to distilled spirits, and therefore is providing certain exemptions and authorizations to distilled spirits permittees who wish to produce ethanol-based hand sanitizers to address the demand for such products during this emergency. Any existing DSP therefore can immediately commence production of hand sanitizer or distilled spirits (ethanol) for use in hand sanitizer, as described below, without having to obtain authorization first. These measures are generally authorized under authorities that apply in disaster situations, and as a result, are initially approved through June 30, 2020, with the…