QUESTION: We are undergoing an audit in NL. The Customs Agency wants to review the Transfer Price and the TP methodology at which we sell our products to related parties and the price we sell our product to unrelated parties in NL. They asked our consultants in NL to have us (in the USA) provide […]
Add’l Answer: You can hire counsel if you like spending money. But if your product meets the requirements listed in the MTB, you are allowed to claim the MTB. We claim a MTB which we did not request, I reviewed the provisions, checked off the boxes that it qualified and then I informed our Account […]
QUESTION: I understand that these two countries do not allow ex works shipments (out of the US), has anyone heard the same thing and is there any basis for this? Thanks ! ========== Answer: I’ve never heard of any country ‘not allowing’ ex works shipments. There could be logistical challenges and you have to arrange […]
QUESTION: I have a question regarding the Huawei restrictions. If we are an American Based and owned company can our locations in foreign countries do business with Huawei if the items do not come into the United States ========== Answers: The restrictions include re-export of items/technology covered by the EAR, so – it depends. Depending […]
QUESTION: I’m looking for thoughts on End User Statements and whether your company uses them? It is a “Best Practice” on all the government trade sites and we have incorporated them into our compliance program. Most of our products are classified as Dual Use, and are EAR99 and we only request them for exports. […]
QUESTION: I know we have sanctions and embargoes on NK, IRan, Cuba which limit our ability to trade with these countries without certain licenses, exceptions and approvals. I was surprised to learn recently though that a US citizen can travel to Iran, Cuba or NK without an issue. Is this correct? I always thought […]
QUESTION: FACTS Company A resides in the United States Customer resides in Mexico Customer designates a freight forwarder in Texas Company A ships to freight forwarder in Texas and receives payment from Customer in Mexico QUESTIONS Is this a routed transaction? Who files the EEI? Should the Freight Forwarder be requesting Company A’s EIN? Should […]
QUESTION: My company is developing a global valuation standard. We’d like to add an appendix list of FOB vs CIF value countries. Does anyone know of a published list where we can get that information? ========== Answer: The vast majority of WTO countries are CIF. I’m not aware of a formal list, but the FOB […]
QUESTION: I’m new to the area of software downloads and need some best practices. Obviously, it’s easy to ban IPs in Iran, North Korea, etc. But is that enough? How do I guarantee that a prohibited national isn’t downloading the EAR99 software another way, in another country or by masking his IP address? I guess […]
QUESTION: We are a manufacturer of paper/plastic products all EAR99. We don’t sell medicine, agriculture commodities, or medical devices. If we conduct denied parties screening, would it be safe to exclude Sudan from the restricted countries list or there are other restrictions I should be aware of? BIS mentions CCL based controls §742.10 (not applicable to […]
QUESTION: Scenario: Drapery sold to cruise line for guest rooms ion the vessel Goods to be shipped to Miami, FL to the customer’s (cruise line) agent Goods to be placed on non-US cruise ship in Miami prior to sailing Question: Is this considered a US domestic move because the goods were loaded in Miami, or […]
QUESTION: Below is a response that was given to a question posed last August. Does anyone know if Census has provided any new guidance regarding the use of 98 for exports when 98 was not used at time of import? RESPONSE: “This question has been presented to Census as part of the Aerospace Industry Association’s […]
