Christine Dower

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Christine is a litigation and regulatory compliance attorney who concentrates her practice within the Alcohol Beverage and Cannabis Industries. As a member of the Firm’s Chambers-ranked Alcohol Regulatory & Distribution Group, Christine counsels industry clients on trade practice issues, tied-house compliance, state franchise law, state and federal licensing, e-commerce, distribution agreements, third-party alcohol delivery for sale of beer, wine and spirits and other alcohol beverages. Christine also conducts alcohol and cannabis regulatory due diligence for corporate restructures, mergers and acquisitions.Read Christine Dower's full bio.

Navigating the Buzz: How State Agencies Are Addressing Confusion Around Hemp and Low-Dose THC Beverages


By and on Oct 25, 2024
Posted In Cannabis, Hemp-Derived Beverages, Non-Alcoholic Beverages, THC Beverages

Hemp and low-dose delta-9 tetrahydrocannabinol (THC) beverages continue to flood the marketplace. Depending on the state, these products can be purchased in liquor stores, gas stations, grocery stores, bars, restaurants, and/or online. Despite their rise in popularity and presumed legality under the 2018 Farm Bill, some state agencies have recently made headlines with decisions to ban...

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Contract Manufacturing Versus an Alternating Proprietorship: What Is the Difference?


By , and on Sep 26, 2024
Posted In Alcohol Excise Taxes, Audits, Commercial Agreements, Craft Beverage Modernization Act, Licensing

We frequently receive questions about the differences between contract brewing and alternating proprietorships, as well as questions concerning the key details the Alcohol and Tobacco Tax and Trade Bureau (TTB) and other regulators will be looking for in either approving the proposed structure or, more importantly, during a company audit. Here we discuss the primary...

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TTB Ramps Up Tax Audits and Enforcement


By , and on Mar 19, 2024
Posted In Alcohol Excise Taxes, Enforcement, Licensing

The Alcohol and Tobacco Tax and Trade Bureau’s (TTB) Office of Field Operations is responsible for ensuring industry members comply with the Federal Alcohol Administration Act, the Internal Revenue Code and all related regulations. It is divided into three groups: the Trade Investigations Division (TID), the Tax Audit Division (TAD) and the Intelligence Division. Many...

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Navigating Hemp THC Beverages


By and on Mar 4, 2024
Posted In Cannabis, Food Safety and FDA

Nonalcoholic beverages infused with delta-9 tetrahydrocannabinol (THC) derived from hemp (aka intoxicating hemp beverages) are becoming increasingly popular for consumers looking for an alternative to alcohol. With major alcohol retailers like Total Wine entering the cannabis space, alcohol beverage producers may be looking for opportunities to leverage their existing experience in manufacturing, marketing and distributing...

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Alcohol Industry M&A: Common Pitfalls for Founders (and Avoiding Them) Part One: Formulas and Processes


By and on Oct 30, 2023
Posted In Transactions, TTB COLAs and Formulas

Given the continued strength of the US alcoholic beverage market, the alcohol industry presents numerous opportunities for acquisitions, investments and other strategic transactions from a wide variety of players. These range from small craft start-ups to larger strategic buyers, as well as investors of all shapes and sizes. In such a highly regulated industry, however,...

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Non-Alcoholic Beer Regulation 101


By and on Jun 25, 2020
Posted In Advertising and Marketing, Distribution, Food Safety and FDA, Legislation, TTB COLAs and Formulas

As part of the general move to better-for-you beverages, non-alcoholic (NA) options have been and will likely continue to be on the rise. However, how NA is treated, or not treated, as “beer” has significant impact on its potential route to market. The below summarizes the overall treatment of NA beer under US federal law,...

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