So, on 29 June, as you know, various requirements begin related to the PACT Act.
One of these requirements is:
"‘(c) Records-
‘(1) IN GENERAL- Each delivery seller shall keep a record of any delivery sale, including all of the information described in section 2(a)(2), organized by the State, and within the State, by the city or town and by zip code, into which the delivery sale is so made.
‘(2) RECORD RETENTION- Records of a delivery sale shall be kept as described in paragraph (1) until the end of the 4th full calendar year that begins after the date of the delivery sale.
‘(3) ACCESS FOR OFFICIALS- Records kept under paragraph (1) shall be made available to tobacco tax administrators of the States, to local governments and Indian tribes that apply local or tribal taxes on cigarettes or smokeless tobacco, to the attorneys general of the States, to the chief law enforcement officers of the local governments and Indian tribes, and to the Attorney General of the United States in order to ensure the compliance of persons making delivery sales with the requirements of this Act."
So, my question is, do the distributors start their retention/access as of 29 June or do they provide access to the last 4 years worth of records as well on 29 June?
Maybe it is better to deal with non-PACT compliant vendors until 29 June?
Or has this already been factored in?
I hate the uncertainty of rule changes.
One of these requirements is:
"‘(c) Records-
‘(1) IN GENERAL- Each delivery seller shall keep a record of any delivery sale, including all of the information described in section 2(a)(2), organized by the State, and within the State, by the city or town and by zip code, into which the delivery sale is so made.
‘(2) RECORD RETENTION- Records of a delivery sale shall be kept as described in paragraph (1) until the end of the 4th full calendar year that begins after the date of the delivery sale.
‘(3) ACCESS FOR OFFICIALS- Records kept under paragraph (1) shall be made available to tobacco tax administrators of the States, to local governments and Indian tribes that apply local or tribal taxes on cigarettes or smokeless tobacco, to the attorneys general of the States, to the chief law enforcement officers of the local governments and Indian tribes, and to the Attorney General of the United States in order to ensure the compliance of persons making delivery sales with the requirements of this Act."
So, my question is, do the distributors start their retention/access as of 29 June or do they provide access to the last 4 years worth of records as well on 29 June?
Maybe it is better to deal with non-PACT compliant vendors until 29 June?
Or has this already been factored in?
I hate the uncertainty of rule changes.
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