MULTIPLE TRADE NAMES
Manufacturers of tobacco products:
Purpose. This industry circular is to advise you of a ruling
concerning the use of multiple trade names by a manufacturer of
Background. In the past, it has been our position to limit
trade names of a manufacturer of tobacco products to a single trade
name. However, we have recently reconsidered this position and have
issued a ruling in the matter.
Substance of ruling. Where a manufacturer of tobacco products
desires to use more than one trade name, the addition of a trade
name is a "change in trade name" within the meaning of 26 CFR 270.92.
Therefore, if such trade name is in fact used in connection with
his manufacturing operations, the manufacturer is required to make
application, on Form 2098, for an amended permit in accordance with
that section. A trade name approved by the assistant regional
commissioner (alcohol and tobacco tax) may be used on packages of
tobacco products as the name of the manufacturer removing such products
subject to tax as provided in 26 CFR 270.212.
Inquiries. Inquiries in regard to this industry circular should
refer to its number and be addressed to the office of your assistant
regional commissioner (alcohol and tobacco tax).
Dwight E. Avis
Director, Alcohol and Tobacco Tax Division