So you mean like Vonage?  That would get you out of filing 477 but not 499, and 
once you start filing 499, you will get assessed TRS and NANP fees, unless 
there’s a way to get exempted from that.

 

Yes you can probably fly under the radar, but I get scared that FCC will decide 
to fine us $25K for not filing some paperwork.

 

 

From: Af [mailto:af-boun...@afmug.com] On Behalf Of Josh Reynolds
Sent: Thursday, October 13, 2016 11:38 AM
To: af@afmug.com
Subject: Re: [AFMUG] reselling SIP

 

For a non-facilities based provider?

IANAL either, but that doesn't sound right I don't think.

 

On Oct 13, 2016 11:23 AM, "Ken Hohhof" <af...@kwisp.com 
<mailto:af...@kwisp.com> > wrote:

You still have to file a bunch of paperwork and are subject to rules like CPNI 
and possibly outage reporting, plus surprise surprise, you still have to pay 
some fees like TRS and NANP.

 

From: Af [mailto:af-boun...@afmug.com <mailto:af-boun...@afmug.com> ] On Behalf 
Of Adam Moffett
Sent: Thursday, October 13, 2016 11:16 AM
To: af@afmug.com <mailto:af@afmug.com> 
Subject: Re: [AFMUG] reselling SIP

 

Something like that.  IANAL either, but I think there are still lots of people 
flying under the radar on this issue.  If the underlying carrier is doing the 
taxes and USF and such then there might not be any red flag there where 
somebody would notice.

 

That doesn't mean your compliant with the law and it doesn't mean the correct 
taxes are being paid.  

 

I did learn at one point that if your USF contributions total less than $10,000 
/ year that you're a "de minimus" provider and you're just supposed to keep the 
money.  You might want to look into getting it done right....There must be a 
level of volume where the legal and accounting expense is covered by the USF 
fees you would have to collect.

 

 

 

------ Original Message ------

From: "Ken Hohhof" < <mailto:af...@kwisp.com> af...@kwisp.com>

To:  <mailto:af@afmug.com> af@afmug.com

Sent: 10/13/2016 11:41:42 AM

Subject: Re: [AFMUG] reselling SIP

 

IANAL, but I believe the deciding factor is who bills the customer for the 
voice services.

 

 

From: Af [mailto: <mailto:af-boun...@afmug.com> af-boun...@afmug.com] On Behalf 
Of That One Guy /sarcasm
Sent: Thursday, October 13, 2016 10:29 AM
To:  <mailto:af@afmug.com> af@afmug.com
Subject: [AFMUG] reselling SIP

 

We resell some SIP trunks with PBX we install on our contract services side. We 
are not the SIP provider in any way, but we do get paid. if its traversing our 
ISP network does that technically make us a voice provider, or are we still 
able to hide out as an ISP


 

-- 

If you only see yourself as part of the team but you don't see your team as 
part of yourself you have already failed as part of the team.

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