Gray Robinson

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Taste, Toast, Zoom: Virtual Tastings, Mixology Classes, and Experiential Events

Virtual Alcohol Tastings and Mixology Classes: Virtual alcohol tastings and mixology classes are not an entirely new concept; however, they have gained popularity as a result of the COVID-19 pandemic and necessity due to local and state orders. Virtual tastings and mixology classes come in the form of a recorded or live online guided sampling ...
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Top 10 Things I Wish I Knew About My Liquor Licensed Premises

Today’s category is…..The Top Ten Things I wish I knew about my Liquor Licensed Premises! #10: I need to submit an update to the governing licensing authorities when I restructure, change an officer, or change a d/b/a name. Disclosures on licensing applications should be accurate and current, so that the regulating authority has a record ...
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unlabeled bottles of alcohol

TTB Clarifies Trade Practice Enforcement for COVID-19-Related Activities

The Federal Alcohol and Tobacco Tax and Trade Bureau (“TTB”) published a May 8, 2020 Industry Circular #2020-3 titled, “Trade Practice Enforcement During COVID-19 Pandemic”, which provides helpful insight into the agency’s current stance on various trade practice issues during the COVID-19 pandemic. The Industry Circular addresses five main categories of activity: Product Returns; Extension ...
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COVID-19’s Impact On Extensions of Credit and Returns in the Alcohol Beverage Industry

The ripple effects of governmental response to COVID-19 are being felt in all tiers of the alcohol beverage industry. State and local orders closing restaurants, bars, and other on-premises retailers of alcoholic beverages have left many retailers trying to find creative ways to recover their losses. One solution to recover cash and prevent waste is ...
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State & Federal Alcohol Compliance Update: TTB Enforcement and Related Matters

The U.S. Department of the Treasury, Tax and Trade Bureau (TTB) is the federal agency with oversight of alcohol beverage sales, marketing, and distribution. Every U.S. state has a companion state-level agency to TTB. In recent months, TTB has, thanks to a generous allocation in the federal budget, embarked on a rigorous trade practice investigation ...
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Best Practices in Trade Practices

Introduction After the Prohibition was repealed by the 21st Amendment, a complex web of alcohol beverage laws created a “three-tier system” in which independence must exist between alcohol beverage manufacturers, distributors, and retailers. The ways in which these three tiers can interact is strictly controlled by federal and state laws. Armed with an increased budget ...
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Liquor Licensing For Hotel & Restaurant Acquisitions

You are the General Counsel or the outside counsel to a hotel or restaurant brand. Your client informs you that the company intends to purchase multiple units of additional properties in several different states. Your head spins, full of questions. Will it be an asset sale or stock purchase? Will we retain the employees? Will ...
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Alcohol Advertising in the Digital Age

Introduction Suppliers and retailers of alcoholic beverages advertise their respective products and offerings in a wide variety of digital outlets. Questions arise as to how the complex legal landscape of alcohol regulation applies in these digital spaces. Advertising media include social network services (e.g., Facebook), video sharing sites (e.g., YouTube), blogs, and smartphone applications. In ...
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FDA Will Begin Enforcing Menu Labeling Requirements in Less Than Two Months: Covered Establishments Must be Prepared

After many delays, the U.S. Food and Drug Administration is slated to begin enforcing its menu labeling rule on May 5, 2017. The Food Labeling; Nutrition Labeling of Standard Menu Items in Restaurants and Similar Retail Food Establishments rule, codified at 21 CFR 101.11, applies to retail food establishments with twenty (20) or more locations. ...
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