[VoiceOps] USF and Minimum Billing

Paul Timmins paul at timmins.net
Wed Dec 2 23:06:34 EST 2015

IANAL but that's how I read it too. USF is to be levied on interstate services (of which voip is automatically because internet) and a contract shortfall is neither federal in jurisdiction nor a telecommunications service.

> On Dec 2, 2015, at 19:23, Peter Beckman <beckman at angryox.com> wrote:
> 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?
> Beckman
> ---------------------------------------------------------------------------
> Peter Beckman                                                  Internet Guy
> beckman at angryox.com                                 http://www.angryox.com/
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