Continuing my in-depth analysis of the excise tax from Part 2
Reporting Requirements
Every system will create a Brewer’s Report for you, but you must file it either by mail or electronically via pay.gov. I personally like to file and pay electronically, but the setup can be a bit daunting. In order to create a pay.gov account, you’ll need to prove who you are and that you have the rights to sign the tax return. All of those documents go to a person who creates the user id and password.
No matter which form you use, all tax returns are due by the 15th of the following month. Keep in mind that it may take a few days for the electronic debit to hit the account, so I would file and pay as soon as you have the numbers for the previous month. One quirk in tax reporting is the special rules that apply each September: there is a third return due in September. Brewer’s Reporting periods are as follows:
1-15th for all filers
16-25th (for non EFT filers)
15-26th (for EFT filers)
26-30th(for non EFT filers)
27-30th for EFT filers)
Excise Tax returns have similar reporting periods. You can file annually if you have $1,000 or less in tax for the current and prior year and is due on the 14th day after the close of the calendar year. Tax liability of $50,000 or less require a quarterly return. Quarters end at the end of the month of March, June, September, and December. Returns are due 14th day after the close of the quarter. If your tax liability is over $50,000 then you must file semi-monthly with returns from 1st to the 15th of the month and the 15-to end of month. Those returns are due the 14th day after the close of the period.
A common mistake that new breweries make is that they will receive their brewer’s notice and not file returns. Even if you are not brewing beer, it is important to file the brewer’s report and tell the TTB that you did not brew beer. Otherwise you could be facing penalties and interest that are completely avoidable.
Document Storage Requirements
Every brewery is required to keep records that will keep a record of operations throughout the brewery. Those records include:
- Daily Report of Operations
- Inventory Records
- Brewer’s Report of Operations
There are very few specific requirements, but the records must maintain the required information and will be reviewed by TTB at their request. The TTB has a field audit staff and they will do onsite inspections. These records can be individual invoices or printouts from brewing accounting systems and should include the brewer’s report of operations and the excise tax return. It is important to note that transactional records must be completed by the end of the next business day and photocopied records are considered to be original documents.
Excise tax records must be kept for three years, but may be kept for an additional three years if requested by the TTB and are generally stored onsite and available to the TTB during regular business hours. These records can be kept off site, but must be retrievable within five days.
