Reports on Forms 52-D and 45 of Products
Bottled or Packaged Especially for Export
Proprietors of taxpaid bottling houses
and rectifying plants:
1. The purpose of this circular is to advise proprietors of
taxpaid bottling houses and rectifying plants of reduced requirements in reporting on Forms 52-D and 45, respectively, distilled
spirits and wines bottled or packaged especially for export with
benefit of drawback under the provisions of the regulations in
26 CFR Part 252,
2, Proprietors of taxpaid bottling houses and rectifiers
are no longer required to declare an intention to bottle or
package, or rectify and bottle or package, distilled spirits or
wines especially for export with benefit of drawback. Accordingly,
certain reporting requirements of Forms 52-D and 45 are no longer
necessary. Pending appropriate revision of these forms, the
following information is provided in regard to such requirements.
Taxpaid Bottling Houses
3. Products Dumped and Bottled Form 52-D. It is no longer
necessary to identify in part 2, columns 8 and 14, nor separately
report in part 5, columns I through 6, on lines 13 and 17, products
dumped for bottling for export. This will result in such products
being considered as, and included in, the totals of distilled spirits
and wines for domestic purposes reported in part 5, columns 1 through
6, lines 1 through 12, and 14, 15, and 16. However, products
bottled especially for export with benefit of drawback will continue
to be identified in part 2, column 19, and to be reported separately
in part 5, columns 7 and 8, lines 13 and 17.
4. Products Packaged Form "52-D. It is no longer necessary
to report distilled spirits and wines dumped and packaged for export
with benefit of drawback on a separate page of part 2 of Form 52-D.
However, part 2 will include all products dumped, whether ultimately
bottled or packaged for domestic or export purposes, and packages
filled for export will be reported in part 2, columns 17 to 21, on
a separate line from bottles filled from the same lot. Such entries
will be identified in column 17 by the symbols "Pkgs." and in column
19 by the symbols "Exp.". In such case, the total quantity of
unrectified products in packages should be separately reported in
part 4, columns 1 and 2, at new lines 14 1/2 and 30 1/2 designated
"Unrectified products packaged for export (Part 2, columns 20 or 21,
unrectified "Pkgs." for "Exp." items)" and the total quantity of
rectified products in packages separately reported in part 4,
columns 1 and 2, at new lines 15 1/2 and 31 1/2 designated "Rectified
products packaged for export (part 2, columns 20 or 21, Rectified
"Pkgs." for "Exp." items)."
5. Repackaging of Products Stored on Premises, Form 52-D. Products
removed from case storage or export storage or bottling or packaging
for export may be reported in part 2, in the same manner as any other
products dumped for bottling or packaging as described in paragraphs
3 and 4. Such removals will be reported in part 40 at lines 23, 34, or
35, as the case may be, and at line 3. The line designations will be
revised to show that the transaction was for "packaging" "bottling,"
"repackaging," or "rebottling," as applicable. The heading over columns
3 through 6 of part 3 may be revised to read "Products Removed for
Packaging, Bottling, Repackaging, or Rebottling" in order that such
heading may be descriptive of the actual transactions.
Rectifying Plants
6. Products Dumped end Bottled or Packaged, Form 45. It is no
longer necessary to identify products dumped for rectification and
bottling or packaging especially for export with benefit of drawback,
or products dumped for bottling or packaging (without rectification)
for that purpose, in part 2, column 6, or part 4, columns 8 or 14, nor
to report such products separately in part 7, columns 1 through 9, line
15. Such products will be included in the totals of distilled spirits
and wines for domestic purposes reported in part 7, columns 1 through
9, lines 1 through 14. It is no longer necessary to identify packaged
rectified products to be bottled for export in column 16 of part 3.
Column 16 of part 3 should identify products rectified and packaged
for export, as well as rectified products bottled for export. Entries
of products bottled for domestic consumption and entries of bottling
for export should be made on separate lines in the order of their
bottling. Similarly, products bottled especially for export with
benefit of drawback will continue to be identified in part 4, column 19,
and will be reported separately in part 7, columns 10 and 11, line 15.
7. Products Packaged Without Rectification, Form 45. It is
no longer necessary to report distilled spirits and wines dumped
and packaged for export with benefit of drawback on a separate
page of part 4 of Form 45. However, part 4 will include all products
dumped for bottling or packaging without rectification, whether for
domestic or for export purposes, and quantities in packages filled
for export will be reported in part 4, columns 17 through 21, on a
separate line from quantities in bottles that may be filled from
the same lot. Such entries will be identified in columns 17 by
the legend "Pkgs." and in column 19 by the legend "Exp.". The total
quantities in such packages should be reported separately in part 6,
at new lines 25-1/2 and 48 1/2, designated "Unrectified Products
Packaged for Export (part 4, column 21, Unrectified "Pkgs." for
"Exp." items)" or at new lines 26 1/2 and 45 1/2 designated "Repackaged rectified products (part 4, column 21, rectified "Pkgs." for
"Exp." items)," as the case may be. The heading over columns 7
through 9. of part 7 should be revised to read "Unrectified Products
Dumped for Bottling or Packaging."
8. Repackaging of Products Stored on Premises, Form 45. Products
removed from the finished products room or export storage room for
bottling or packaging for export may be reported in part 2 or 4 in
the same manner as any other products dumped for bottling or packaging
as described in paragraphs 6 and 7. Such removals for dumping will
be reported in part 6, at lines 38, 39, 52, or 53, as the case may be,
and at line 3. The line designations will be revised to show that
the transaction was for "packaging," "bottling," "repackaging," or
"rebottling," as applicable. The headings over columns 3 through 6
of part 5 should be revised to read "Products Removed for Packaging,.
Bottling, Repackaging, or Rebottling", in order that such heading
may be descriptive of the actual transaction.

Dwight E. Avis
Director, Alcohol and Tobacco Tax Division
IRS-18100 |