EDUCATIONAL ADVISORY – Regulatory Fee Implications of Various International Transmission Scenarios


ATTENTION INTERNATIONAL TELECOMMUNICATIONS PROVIDERS:  Important Guidance on the Proper Regulatory Treatment of Various International Call Path Scenarios

The FCC has provided very little guidance to assist international service providers in correctly categorizing international service revenues for Form 499-A reporting purposes. Providers, therefore, have been left to interpret the FCC’s intent as embodied in the Form 499-A instructions, and risk reclassification of revenues (with potentially devastating financial consequences) in the event of an unfavorable Universal Service Administrative Company (“USAC”) audit decision. In recent audits, USAC has taken some surprising positions relative to the classification of certain revenue streams from international traffic.

To aid companies in navigating the complexities of international revenue reporting, our firm has prepared this Educational Advisory. Along with this Advisory, we have prepared an overview of common “Call Path” scenarios encountered by various international wholesale and other “In-the-Middle” telecommunications and VoIP transmission providers.

FCC Regulatory Fee Implications of Various International Call Paths Commonly Sold by Wholesale and In-the-Middle Transport Carriers

This Advisory and the accompanying presentation do not provide legal advice, but aim to arm companies with the tools to evaluate their international revenue reporting and identify issues that may warrant further examination with counsel.

ATTORNEY ADVERTISING DISCLAIMER: This information may be considered advertising in some jurisdictions under the applicable law and ethical rules. The determination of the need for legal services and the choice of a lawyer are extremely important decisions and should not be based solely upon advertisements or self-proclaimed expertise. No representation is made that the quality of the legal services to be performed is greater than the quality of legal services performed by other lawyers

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