Reminder to Alcoholic Beverage Licensees: Annual TTB Filing Due July 1, 2024
Businesses that sell or serve alcoholic beverages, such as liquor stores, grocery stores, bars, and restaurants, not only must obtain the appropriate retail license within the jurisdictions in which they operate, but are also subject to Alcohol Dealer Registration with the Alcohol and Tobacco Tax and Trade Bureau (TTB) within the U.S. Department of the Treasury. This often overlooked registration requirement must be satisfied prior to commencement of alcoholic beverage sales, and any changes in the ownership of the business, business locations, and certain other information must be disclosed annually in a filing that is due July 1. The registration requirement arises from Title 26 of the United States Code (specifically, Subtitle E, Chapter 51 of the Internal Revenue Code) and applies to any “dealer,” which is defined in 27 CFR § 31.1 as “[a]ny person who sells, or offers for sale, any distilled spirits, wines, or beer.” Thus, retail dealers include liquor stores, restaurants, bars, private clubs, fraternal organizations, grocery stores, supermarkets, hotels, sports stadiums, caterers, trains, aircraft, and vessels. Wholesalers and importers are also included within the definition of “dealer.” Subject to certain exceptions, both retail dealers and wholesale dealers must comply with the applicable registration requirements. Registration entails filing TTB Form 5630.5d before engaging in business and on or before July 1 of each...