[VoiceOps] USF and Minimum Billing

Peter Beckman beckman at angryox.com
Wed Dec 2 21:23:39 EST 2015

Hey Folks --

I've got a carrier to which I've made a minimum commitment. I didn't get
around to getting my spend up to the commit, and when my contract renewed,
they billed me a minimum commit fee. Understandable, and I'm fine paying
it. I didn't get anything for it -- zero telecom-related services.

However, they also charged the USF percentage on the minimum fee.

The Language from the FCC leads me to believe that this carrier's
assessment of the USF on minimum billing is incorrect and illegal, as that
fee is not interstate nor international end-user revenues. For specific
detail, FCC Form 499-Q item 115 clearly states that the USF is to be
taxed on:

"Telecommunications provided to other universal service contributors for
resale as telecommunications or as interconnected VoIP"

The minimum fee is not telecommunications.

Additionally Form 499-A for Line 418 states:

"Line 418. — Other revenues that should not be reported in the contribution
bases; Non-interconnected VoIP Revenues. Line 418 should include all
non-telecommunications service revenues on the filer’s books, as well as
some revenues that are derived from telecommunications-related functions,
but that should not be included in the universal service or other fund
contribution bases. For example, information services offering a capability
for generating, acquiring, storing, transforming, processing, retrieving,
utilizing, or making available information via telecommunications are not
included in the universal service or other fund contribution bases."

Anyone else experience this? Or have any background? I do not believe the
carrier should charge me nor pay the FCC the USF on non-telecom fees.

Any Telecom lawyers out there?

Peter Beckman                                                  Internet Guy
beckman at angryox.com                                 http://www.angryox.com/

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