On April 1, 2014, the Ad Hoc Coalition of International Telecommunications Companies (“Coalition”) filedComments and, alternatively, a Petition for Rulemaking asking the FCC to adopt a variety of new rules aimed at improving the fairness and equity of USAC’s administration of the Universal Service Fund (“USF”) program. Specifically, the Coalition asked the FCC to adopt rules to:
- Allow telecommunications carriers to request guidance from USAC on an anonymous and hypothetical basis (similar to the “Letter Ruling” process available at the Internal Revenue Service and many state tax authorities);
- Establish a five-year look-back period for all USAC audits and contribution obligations; and
- Create amnesty and/or voluntary disclosure agreement programs for well-intentioned telecommunications and interconnected VoIP service providers who may not be in compliance with the Commission’s USF regulations.