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 Post subject: US - Taxes and Fees
PostPosted: Sat Mar 27, 2010 8:02 pm 
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Joined: Sun Dec 27, 2009 8:39 pm
Posts: 80
Ah yes, taxes/fees, etc. Here in the US, taxes and regulatory fees are interesting to say the least and getting even more on a daily basis...

The current method of implementing the taxes simply does not work. Applying taxes globally at the client level, does not satisfy the needs of any provider in the US. Because of the intricacies of the line items and what taxes apply to each, the global customer level approach doesn't cut it. The taxes need to be applied at the product/services/rates levels.

Basically, I guess I'm looking for say 3 levels of taxes that can be applied to a product. TaxA, TaxB, TaxC. Each of these would be one of the above, say 1 federal, 1 state, 1 local. At the product level we would select TaxA and the State/Local (TaxB/C) ones would change based on the customer's billing location. I don't know if this would work for those of you in other states (we're in Florida), but I think it would for the most part.

Take a look at the monthly report we need for Florida - http://dor.myflorida.com/dor/forms/2010 ... 6_0110.pdf - it may help.

Here's the way I think it could be implemented, by those much more capable than I...

- Global/Universal Settings
+ Markets - This would allow the users to define what markets each product/service is available in. Market could be US, EU, etc. Maybe a global flag to use or not use would allow those not interested to skip...
+ Tax A - This would be the top level, say Federal Taxes. These would be locked down to the market, so as the products/customers are separated into Markets, the levels would be defined.
+ Tax B - State Taxes - Each State has a communications tax, and this would be assigned at the Customer level.
+ Tax C - Local Taxes - Each of the States is broken down into Local regions. The problem here is that between Tax B and Tax C is a County, or at least in Florida there is and there's 67 of them. Each county needs to be broken down individually when reporting the taxes that were collected.
+ Locations - A Hierarchical structure belonging to Markets that would allow admins to separate customer locations. For example, here in the US, I would want to define the State, County, and City/Municipality. Here in Florida, Miami-Dade County has over 30 different taxing districts (rates) for the Local portion of the tax, Tax C
+ LATAs - This would allow us to define the LATA that each customer is located in. This would allow local calling plans to include free calling in the customer's region. Lata's could be part of the structure above, but LATA's may include portions of counties, and may lead to duplication of counties.
+ The locations/Lata's above would each have a set of "local" prefixes. Some Lata's go down to the Exchange, when an area code is shared.
+ Each Location/Lata would have a "tax" level associated with each, or defined underneath it. These Tax levels (Federal/State/Local)could be defined elsewhere.
+ The tax levels (A-C) should also have start/end date. USF Fees for the second quarter are going up to 15.3 from 14.1. A method similar to the rates with an expiry would work.
+ Prefixes would allow selection of Market/Location/Lata so that reporting could be broken down by any of these.

- Each Customer would need to have:
+ A market/location/lata defined. This would allow the further selection of the location.
+ A tax location defined. The tax location would be the set of taxes that apply to this customer at "local" levels. In our case, the Local would be a State and a Local. This would correspond to a Tax B and Tax C.
+ A set of Local prefixes, so that all other prefixes are considered Long Distance. This would either override or append the Location's local settings.

- Each Product/Service would need to have:
+ A product may also be subject to no tax, as there are certain regulatory fees that can be recovered from the customer that do not incur taxes. So a taxable/non-taxable flag would also need to apply.
+ A set of applicable taxes. Because of the complexity of the taxes, each product would incur one level of Federal Tax, and then the State/Local Tax (if applicable), based on the customer's billing location.

- On the Invoices:
+ Taxes would need to be individually listed at the end of the invoice. Federal Tax, State Comm Tax, Local Comm Tax, USF. We don't need to identify what line items on the invoices they applied to, they just need to be broken down.

- Reports
+ Because the FCC USF fees are based on interstate/international usage based on the customers' billing location, we need to be sure that as a customer's inbound/outbound usage is billed/rated that we can later identify each customer's local/interstate traffic. In order to file the 499-Q forms, we need to know the international/interstate and local traffic for all customers according to each customer's usage.
+ Reports by Location. As VoIP Providers, you need to register to collect tax in each state you send a bill to.

This is going to be fun...

I'm willing to seriously contribute to this (at least $1k USD), if others are interested in "chipping" in, as any provider of interconnected VoIP in the US (Calling cards too) is going to be in a lot of heat, if they don't do taxes properly. Unfortunately, it's not as easy here in the US to slap a2billing together and start making money.

At this time, we are looking at some hosted solutions to import our CDR's and break the bills down for us. The headaches as we grow to manually separate the items out to bill the customers is starting to take up too much time.


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 Post subject: Re: US - Taxes and Fees
PostPosted: Wed Aug 25, 2010 3:32 pm 
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Joined: Wed Aug 25, 2010 3:26 pm
Posts: 8
I had not realized that this was going to be an issue. I just assumed that A2Billing would have some flexibility in adding fields to an invoice, but shame on me for not listening to the old addage concerning "assume-ing". :(

I would be willing to contribute to this as well, as I need this in order to "go live".

Alfred


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 Post subject: Re: US - Taxes and Fees
PostPosted: Wed Aug 25, 2010 5:12 pm 
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Joined: Fri Jun 23, 2006 3:56 pm
Posts: 4065
Hi

I'm going to put the following argument forward for discussion, and those who are far more familiar with US law may be able to clarify.

Clearly in a Post-Paid environment, calls are invoiced for at the end of the month, and a tax is levied on the calls made and other services at a rate appropriate to the service supplied when the customer pays the invoice.

In a Pre-Paid environment, you are sending an invoice out for a Top-up of your account. So there can be no taxes applied at that point in relation to calls they make in the future, as they have not made them.

The basic premise of all taxes, is that they are levied at the point of paying an invoice. An invoice contains a value for the goods or services, and it contains an element of tax pertinent to the goods and services supplied.

At the point that the invoice is prepared, the only tax applicable is the tax on a top-up, which ultimately, when the customer is topped up on A2Billing, they may use that credit for a variety of services you may supply, e.g. DID, Subscriptions, Intra-state calls, Inter-state calls, International calls, recurring charges, support, equipment, and a host of other items, but they have already been invoiced for these services, and paid for them, in advance.

You may have to pay a tax on the services you buy and pass on to your customers, but as you have already invoiced them before, surely there is no requirement to apply tax again, and even if you do, when are you going to do it, you are not going to send them another invoice, because you don't need paying, they've already paid.

Possibly your prices may include an element of tax, because you have to pay it, but you don't need to describe what the tax is, or what percentage the component of tax is on the cost of say a DID or a one minute international call.

In a pre-paid environment, would the law on taxes in the USA be satisfied by publishing a pricelist along the lines of:-

[list=]International call to Outer Japonia = 5c per minute of which 1c is Government tax
Interstate call = 2c per minute of which 0.5c is tax
USA DID = 10USD per month including 1USD in tax[/list]

Food for thought?

Joe


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 Post subject: Re: US - Taxes and Fees
PostPosted: Wed Aug 25, 2010 5:33 pm 
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Joined: Wed Aug 25, 2010 3:26 pm
Posts: 8
I would have to do research on the specific requirements, but my understanding (based on discussion with my peers and in reference to other consulting services):

When you "prepay" for a service, you are esentially opening an account, as if it were a "savings account". In my case, when I prepay for services from our providers they automatically charge me the USF tax on every deposit I make into the account and at the end of the month refund me any taxes paid on funds which were used to pay for non-taxable services (my server, billable hours, etc.)

Things are further complicated in that USF fees are collected and paid for my the wholesale provider up to a certain threshhold but if we exceed a certain amount of sales in a year we are responsible to do it. In either case, we must recover these fees and are required by US law to itemize any fees charged on an invoice. (I will have to look at one of our telecom bills which cite the specific laws)

In addition, other providers break-out these fees, although they may be pre-paid. A "major provider" charges for E911, they have their own "recovery fees" (which are itemized) and they also charge all appropriate taxes. BUT- they only list the base charge in their advertising. So if a company lists that they charge $29.95 per month for unlimited service to the US and Canada they do not list that they also charge an additional $2 for E911 per extension, "recovery" fees of $4.95 per extension plus all of the taxes, etc. This is a standard way of doing business, while I would want to note these additional fees as a footnote and note that competitors charge fees, I need to itemize billing in order to advertise a certain price.

A breakdown of the fees a major VOIP provider charges:


E911 Service Fee (US only)
New York Gross Revenue Tax Surcharge
NY Sales Tax
Regulatory Recovery Fee
State 911 Fee
Universal Service Surcharge

The breakdown of fees:

2 Taxes & Fees are based on Service Address. They include government fees and taxes that we collect and are required by federal, state
or local law to remit to the appropriate governmental entity (including, but not limited to, sales, use, excise, public utility, and E911).
This section may also include certain fees and costs incurred by us a result of providing service, such as universal service fees (USF). We
elect to collect them in order to recover or help defray the costs we incur. These fees, and what is included in the fees, may vary by
locale and may change from time to time without notice.
3 We collect the Regulatory Recovery Fee to recover some of the costs we incur to comply with local, state and federal governmental
mandates and programs, including, but not limited to, E911, local number portability and number pooling. We may impose the fee
whether or not the benefits of any or all of these mandates and programs are available to you in your location.
4 Note that ship time will adjust according to when the order is actually placed.


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 Post subject: Re: US - Taxes and Fees
PostPosted: Wed Aug 25, 2010 5:50 pm 
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Joined: Fri Feb 19, 2010 4:29 pm
Posts: 50
Govt also gives directives on which goods must be put on sale with "MSRP + applicable taxes" price , which goods can be sold "$123.00, all taxes included", and mention
what those taxes are. The businesses usually use those directives.

The following are two examples taken from Apple online store (one from the USA and one from Canada)

<============Apple online Store USA============>
Tax
Tax rate

In accordance with state and local law, your Apple Online Store purchases will be taxed using the applicable sales tax or seller’s use tax rate for your shipping address. The tax listed during checkout is only an estimate. In California, Massachusetts, and Rhode Island, sales tax is collected on the unbundled price of the iPhone.

Your invoice will reflect the final total tax, which includes state and local taxes, as well as any applicable rebates or fees.
Tax-exempt orders

To place an order on behalf of a tax-exempt organization or individual, please call an Apple Store Specialist at 1-800-MY-APPLE. You will need to provide proof of state tax-exempt status for the state where the product is being shipped. The organization or individual name on the order must exactly match the state tax-exempt certificate. Federal tax exemption certificates are not applicable.
<=============================================>

<==================Apple online Store Canada===============>
Tax
Tax rate

In accordance with local law, your Apple Online Store purchases will be taxed using the applicable tax rate(s) for your shipping address. If the tax rate changes before your purchase is shipped, the rate in effect at the time your order ships will apply.

Based on your shipping address, you may see a combination of these types of taxes on your order:

* PST/QST - Provincial Sales Tax and Quebec Sales Tax
* GST - Goods and Services Tax
* HST - Harmonized Sales Tax (GST + PST)

Tax-exempt orders

To place an order on behalf of a tax-exempt organization or individual, please call an Apple Store Specialist at 1-800-MY-APPLE. You will need to provide proof of tax-exempt status for the address where the product is being shipped. The organization or individual name on the order must exactly match the tax-exempt certificate.
<============================================================>

My 2 cents of contribution.


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 Post subject: Re: US - Taxes and Fees
PostPosted: Wed Aug 25, 2010 6:10 pm 
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Joined: Wed Aug 25, 2010 3:26 pm
Posts: 8
i can wholeheartedly say that Joe and Star2Billing have impressed me with their approach to implementation and security.

My comments are concerning A2Billing:

1. A2Billing is an open source initiative and we can only expect so much from it. it is also relatively new as a telecom billing platform.
2. Now that I have been configuring it and actually using it I can see that it really is a calling card billing platform being modified as a VOIP billing platform.
3. Billing by product is OK for calling cards but horrible for services that mave multiple components. For telecom billing it must be customer based where "products" or individual SKU's are created, priced and added to a recurring bill (whether prepaid or post paid) to a specific customer with the ability of adding one time charges and credits to the current billing cycle as well as billing for a variable such as minutes used.


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 Post subject: Re: US - Taxes and Fees
PostPosted: Wed Aug 25, 2010 6:25 pm 
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Joined: Wed Aug 25, 2010 3:26 pm
Posts: 8
continued...

5. it should be internationalized. When consulting i find this is a problem when dealing with a US based product being modified to accept international addresses and telephone numbers. with A2Billing it was originally designed for Europe.

6. because taxes vary from country to country and even from state to state within a country, you should just allow for admins to create various taxes along with tables for "city/state" where users can set the rate per entry in the table and where each sku created has a box with a list of all taxes created where the admin indicates whether or not a tax applies to that specific SKU. Also, customer records should have a list of taxes and a check box where they can indicate whether or not the customer is exempt (non-profits are exempt from certain taxes and fees in the USA and not others, this also varies by state.) This makes it generic enough that it can be modified for any user in any country/state.


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 Post subject: Re: US - Taxes and Fees
PostPosted: Wed Aug 25, 2010 7:19 pm 
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Joined: Fri Jun 23, 2006 3:56 pm
Posts: 4065
Quote:
...I can see that it really is a calling card billing platform being modified as a VOIP billing platform.


That may be the case, but that I do not believe is responsible for the limitations, as it will bill VoIP based business as easily as calling card business.

Where A2Billing maybe could be improved, is that there is basically a one to one relationship between the product (call-plan) and the account. In other words, it is an account based system rather than a customer based system. Effectively. the DB structure does not lend itself to multiple products (call-plans) per customer. To make this change would lead to a term of instability, and as it stands, A2Billing is very stable.

This topic is extremely useful for designing the next generation of A2Billing, and all thoughts and opinions are welcome, particularly ones that can enlighten us as to how the tax process works, so we can take this into account.

I understand that there are different rates of tax depending on whether the call is inter or intra state, and how those taxes are calculated is still something of a mystery to me. When deciding whether a call is intra or interstate, do you look at the physical location of the PBX or endpoint making the call, or do you look at the caller ID delivered by the PBX?

Joe


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 Post subject: Re: US - Taxes and Fees
PostPosted: Wed Aug 25, 2010 7:48 pm 
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Joined: Wed Aug 25, 2010 3:26 pm
Posts: 8
Joe:

The problem is that calling cards are essentially stand alone products and the are either thrown away or recharged, but this is linked to each card. A telecom (VOIP) customer has multiple services (i.e.: DID, extensions, automated attendants, queues, additional DID's for groups, toll free numbers, usage, equipment rentals, calling cards, etc.)

Basically, the way I see A2Billing as it is right now is a Calling Card provisioning and billing platform with built in call accounting functionality. Telecom billing platforms have to be customer based because of all of the services billed for, discounted and/or services. VOIP providers are displacing PSTN and other service providers. imagine if you received a seperate bill for you telephone, wire maintenance, calling card, toll free number and any number of other services being billed by the same company- it would aggrivate you.

As a service business with multiple products and services being offered I can not build packages around all of these services. The easier way is to add different components to the invoice. The simplest analogy I can think of: While some people may want #3 on the menu, others may want to order the Big Mac with fries and no soda, or they may want to add an apple pie. So, sometimes a bundle works, sometimes it does not and sometime we need to do both (#3 with an apple pie and upgrade to large soda and fries)

Calling cards are very simple and straight forward. Not so with more complex telecom services.

As for taxes, I am 99% sure that the issue is not differences in tax rates between inter and intra lata billing. What is billed differently and is affected by state are the non-usage related items. i.e.: Some states require that sales tax be charged on shipping and handling while others do not.

Alfred


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 Post subject: Re: US - Taxes and Fees
PostPosted: Thu Sep 23, 2010 6:08 am 
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Joined: Wed Aug 25, 2010 3:26 pm
Posts: 8
I am investigating a solution. While not the cleanest, I think that for now it may bring the best of two products together. I am looking into using A2Billing for the Least Cost Routing, provisioning and mid-call teardown. What I am considering is paying a developer to write the code to integrate A2Billing and http://Freeside.biz.

Freeside does billing VERY well from what I can see, it also has a nice user interface, several payment gateways, toll free billing, manages taxes very well and is fairly easy to use and configure. It does not handle provisioning and switch side stuff. The integration would allow customer and credit information to pass between Freeside and A2Billing. (i.e.: Only register a customer in one of the systems and if they fund their account it gets sent to A2Billing so that calls do not get cut off)

If anyone is interested in collaborating on this please send me an email.

Best,

Alfred


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 Post subject: Re: US - Taxes and Fees
PostPosted: Thu Sep 23, 2010 12:53 pm 
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Joined: Tue Mar 17, 2009 4:00 pm
Posts: 153
Location: Where the sun shines
I remember working to implement US taxes on a european telco package some 15 years ago.... that was a real nightmare....

the final design was that tax calculation was done by calling an "external" function, with customer id (that allowed to retrieve all details as address), amount to charge, type of service.

The "external" function was actually interfaced with third party packages, off the shelf, that did the actual calculation.

Maybe A2B could replace the "amount * vat" by a function call, that would allow independent development of tax modules (that could be later shared with the community !)

J.


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 Post subject: Re: US - Taxes and Fees
PostPosted: Thu Sep 23, 2010 1:22 pm 
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Joined: Wed Aug 25, 2010 3:26 pm
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Cerien:

The problem is that there are many billing issues with A2B. It just does not bill for telecom services gracefully. The tax issue is something else entirely, which could be dealt with by having the ability to add custom fields to an invoice as taxes and allow for admins to set-up the rates, etc.

Anyway, I am not thrilled about having to use a third party application, but it certainly is better than having to create monthly invoices manually. I am also considering just biting the bullet and investing in creating a package from scratch, but this would be quite expensive and would require a great deal of time, something which I do not have in abundance.

Alfred


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 Post subject: Re: US - Taxes and Fees
PostPosted: Thu Sep 23, 2010 3:00 pm 
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Joined: Tue Mar 17, 2009 4:00 pm
Posts: 153
Location: Where the sun shines
I agree that billing of recurring services may not be as flexible as one could expect, but from my experience, it is a classical marketing complaint !

Creating a US tax calculation algorithm is indeed complex, and needs a lot of time in maintenance of the rates... hence the value of an off the shelf package.

J.


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