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.
