>>>My current issue is, we own transport, we buy big DIA. >>>We also transport to others and we give them access to/sell DIA. Your own transport for internal use.. would not be subject to USFC selling DIA (regardless of how you transport it) would not be subject to USFC (we are assuming that these are over Ethernet / Fiber etc.. not T1/DS3/OC3 etc.)
>>>>They sell ISP service to end users. ok.. that is not your problem :) >>We need to keep ourselves square with USAC, so we either have to “charge” the >>commercial customer (elect to recover) USF the condition on USF Recovery Fee is to treat everyone fairly across the board :) and it does not have to be the same % as what your contribution is .. even though it is becoming the norm to do so ! >>or they have to tell us they are exempt Yes, those exemptions are defined. >>or show they are filing 499s or show de minimus. Disagree with your understanding on this one.... you are still allowed to collect recovery fee from de minimus (Logic, they are allowed to recover and keep those $$ ) Disclaimer: I am not a Telecom Lawyer, but unfortunately have been on both sides of getting shafted with USFC.. so sharing with you all the minute details that we had to learn the hard way ! :) Regards Faisal Imtiaz Snappy Internet & Telecom http://www.snappytelecom.net Tel: 305 663 5518 x 232 Help-desk: (305)663-5518 Option 2 or Email: [email protected] > From: [email protected] > To: [email protected] > Sent: Tuesday, April 24, 2018 1:29:52 PM > Subject: Re: [AFMUG] USF > My current issue is, we own transport, we buy big DIA. > We also transport to others and we give them access to/sell DIA. > They sell ISP service to end users. > We need to keep ourselves square with USAC, so we either have to “charge” the > commercial customer (elect to recover) USF or they have to tell us they are > exempt or show they are filing 499s or show de minimus. > Just trying to make sure I am clear on this. > From: Faisal Imtiaz > Sent: Tuesday, April 24, 2018 11:24 AM > To: [email protected] > Subject: Re: [AFMUG] USF > That is a ref to Mixed Use Private Lines.... there is no ref to "internet" > FWIW, Transport has been subject to USF & Communication Taxes > So if one is purchasing Transport + DIA separately, then yes they can be > subject > to paying USF Recovery Fees. > and Yes, if you are selling Transport to a downstream customer, you can > charge/collect USF Recovery Fees on it. > However DIA port are not. > ADSL on shared pots line becomes subject to USF > however ADSL on dedicated loops delivering internet access (adsl + internet > from > same carrier) would not be subject to USF > etc etc etc. > (FYI.. there is a federal ITNA which should get the ISP's out of Comm Taxes > unless they are in a grandfathered state). > (FCC cannot trump Congress in regards to internet taxation ! ). > Regards. > Faisal Imtiaz > Snappy Internet & Telecom > http://www.snappytelecom.net > Tel: 305 663 5518 x 232 > Help-desk: (305)663-5518 Option 2 or Email: [email protected] >> From: "Adam Moffett" <[email protected]> >> To: [email protected] >> Sent: Tuesday, April 24, 2018 1:09:33 PM >> Subject: Re: [AFMUG] USF >>>>>> The FCC has defined all internet traffic as interstate and a source of >>>>>> USF >>> >>> contributions. >>> When did that happen ? do you have an ref. please ? >> http://www.commlawgroup.com/news/1172-fcc-clarifies-usf-classification-revenue-mixed-use-private-lines >> Something changed about a year ago. I think it's been the case for a long >> time >> that an interstate data connection is subject to USF. I think what changed is >> they decided that the traffic is the determining factor rather than the >> physical connection points, and that Internet traffic must be assumed to be >> interstate. >> Some people on this list have reported getting USF charges of 21% on DIA >> connections. I haven't seen it yet here.
