QUESTION: Can anyone please advise, the best compliant way to declare engineering fees on partial shipments? We are importing an assembling machine which will be shipped during a 12 months period in more than 40 shipments with different Harmonized Tariffs each as we classify the different parts and components of the machine. I know I […]
QUESTION: If we purchase a component from a US supplier and then forward that component to an overseas vendor to add additional components to finish the product and then import the finished product back to the US, do I need to declare the cost of the US purchased component in the dutiable value? The invoice […]
QUESTION: Has the membership ever encountered instances where assists are applicable to finished goods exported intercompany or to end customers? If so, please provide examples? ========== Answer: If I read your question carefully, you are asking whether an assist is applicable to finished goods exported (but you don’t say from where). First, there are a […]
QUESTION: Our corporate Office is located in the U.S. and engineering drawings/design are being completed fully or partially by one of our sister companies in Costa Rica for manufacturing at another sister company in China. Our sister company in Costa Rica is also providing molds to the China manufacturing operation. Are the drawings/designs considered […]
QUESTION: Company A in the US creates a widget and sends to the related party in China Company B. Company B further processes the widget and it is now a product of China. Company B sends it to Vendor M in Mexico. But this is on Consignment so Vendor M doesn’t pay for it but […]
QUESTION: If raw material purchased in the US and provided to a foreign supplier free of charge, must the cost of the raw material be included in the finished product from the foreign supplier when imported in to the US? ========== Answers: Yes indeed. A good example demonstrating this is ruling H057714. Remember, CROSS and […]
QUESTION: With regard to Assists, is there a materiality basis or a minimum value to claim an Assist? ==================== ANSWERS: No ==================== There is no legal or regulatory sanctioned minimum value to claim an assist. George Tuttle III Law Offices of George R. Tuttle, A.P.C. 1100 Larkspur Landing Circle, Suite 385 Larkspur, CA 94939 […]
QUESTION: I’ve been asked to do some research regarding engineering assists for my company. I found that per TAA, 19 U.S.C. 1401a (h), an engineering assist is defined as: (A)(iv) Engineering, development, artwork, design work, and plans and sketches that are undertaken elsewhere than in the United States and are necessary for the production of […]
QUESTION: 1. If we give a UK supplier US tooling drawings to produce tooling to manufacture an Item for us is it considered an assist? I believe we are ultimately paying for the tooling it will be included in a Non-recurring cost 2. We are also supplying Tooling Drawings that we purchased from a foreign […]
QUESTION: Our current process: – Pay tooling charges to the supplier – Supplier send samples for approval – First production order release – Add the tooling value on the first production shipment entry I just discovered that some of the samples approved NEVER get into production. so there was tooling charges that never claimed as […]
QUESTION: If a US company provides a spec drawing to a foreign contract manufacture only -> is this considered an assist? If so, how is this quantified and reported to US Customs? ============================= ANSWERS: If the design/spec drawing were done in the US, they are not assists. If they were done elsewhere, their cost is […]
QUESTION: Process – What import process ensures all Assists are captured? Are there examples of such processes the membership is willing to share? Accounting – Are all Assists to be capitalized and expensed? Compliance – Since multiple functions have the ability to initiate Assists, how is a company able to be 100% compliant with regard […]
