The new tax law doesn’t address the question of whether tax credits in the bill, which reduce the amount of tax paid on wine, apply to wine stored at locations other than the winery where it was produced.
It was already clear that a producer could bring wine stored elsewhere back to his premises where it would be taxed under the “Special Procedure.” But that elevates form over substance, so TTB said it “is authorizing an alternate procedure, in effect through June 30, 2018, under which wine producers will be allowed to tax determine and tax pay wine of their production stored untaxpaid at a BWC without the wine producer being required to physically receive its wine back from the BWC in bond. Rather, this alternate procedure will allow such wine producers to “receive” their wine “in bond” solely through documentation and reporting.” Full details are in Industry Circular 2018-1, here.