Robert L. Anello, ConsultantCONSULTING SERVICES PROVIDED

329 North C Street

Hamilton, OH 45013-3110

Phone: 513-894-4191

FAX: 513-894-4190

I provide a full range of technical and regulatory services to manufacturers of nonbeverage products (MNBP's) for all matters related to distilled spirits tax drawback to ensure compliance with the regulatory requirements of Title 27 Code of Federal Regulations (27 CFR) and with the statutory requirements of Title 26 United States Code (26 U.S.C.).

My area of expertise is the flavor and extract manufacturing industry and the chemical manufacturing industry.

Among the services I provide are:

 interpretation of; and advice on; laws, regulations, guidelines, and policies established by TTB.

 assistance with preparing and filing nonbeverage formulas and drawback claims.

 direct and indirect liaison with TTB.

 conduct on-site regulatory compliance audits and assessments.

 conduct on-site lectures, seminars, and specialized training.

 strategies to decrease drawback rejections and to reduce nonbeverage formula filing with TTB.

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Nonbeverage Formulas and Process:

 Prepare and file nonbeverage drawback formulas and formula amendments.

 Provide technical and regulatory assistance with formulation, preparation, and filing.

 Review client formulas and amendments for technical accuracy and compliance with regulations.

Nonbeverage Drawback claims:

 Prepare and file nonbeverage drawback claims for clients and provide follow-up with TTB.

 Provide technical and regulatory assistance with drawback claim preparation and filing.

 Assist with rectifying any disapproved or rejected claims or act as an liaison between client and TTB.

Registration and corporate change:

 Assist with special tax registration.

 Assist with preparation of corporate change documents and formula adoptions.

 Act on client's behalf as liaison to TTB's National Revenue Center.

On-site lectures, seminars, training:

 Conduct standard prepared lectures. (call to request a list of currently available prepared lectures).

 Conduct on-site or off-site seminars, training, and lectures that are "custom-tailored" to meet specific organizational needs.

Compliance Audits:

 On-site audits to evaluate and advise on recordkeeping adequacy and regulatory compliance.

 Recommend corrective action and provide action plan to respond to recordkeeping deficiencies and/or noncompliance with nonbeverage drawback formulas and recordkeeping requirements.

New concepts and strategies:

 Procedures and strategies to reduce drawback rejections and to reduce formula filing by 50-75% or more!

Main office in the Cincinnati, Ohio area close to the TTB National Revenue Center where drawback claims are processed provides a central location for providing on-site servicing within 12-24 hour notice (subject to schedule) for clients in the central and mid-west areas and within 24-48 hour notice (subject to schedule) for clients in the north-Atlantic and mid-Atlantic areas.

I am available in the New York area on a frequent (monthly or bi-monthly) basis; operating from a New York City location; to provide services to clients located in the New York - New Jersey area.

GENERAL INFORMATION ABOUT FEES AND CHARGES

I usually bill at an hourly rate (plus expenses) for most short-term services. Long-term projects of several days work are billed at reduced hourly rates (and expense charges) usually at daily (per diem) and/or weekly maximums. Some services are billed at a "flat-fee charge".

I do not post my fees and charges on the website. Call my office at 513-894-4191 to discuss fees or to receive a copy of my fees and charges by FAX.