QUESTION: We have many PSCs and protests pending, mostly for 301 refunds, and we will be submitting our value reconciliation this summer. I am concerned about trying to reconcile an entry while a PSC / protest is occurring simultaneously. What are your thoughts? %%%%%%%%%%% ANSWERS: On you open PSC’s and Protest, It is my understanding […]
QUESTION: Have a question about CBP’s Reconciliation Program (Recon). The Recon is available to any importer (IOR). Is the Recon program available to a Non-Resident Importer (NRI) who imports using a Customs assigned number? Also, does Canada and Mexico have a similar Recon Program? What about other countries having a Recon program? ************** Answers: Yes, […]
QUESTION: My Company filed Value recon in Aug 2019 for year ending 2018 which included commodities that had the additional 301 China tariff duty added (25%). Now our products fall under the Product exclusions. Does anyone know if there is a way to file an adjustment against the assist value added on the recon entry? […]
QUESTION: Can you advise how long it takes to apply for and receive approval to participate in reconciliation? Are there any best practices or things that we need to keep in mind related to the program? %%%%%%%%%% ANSWERS: There is no more formal application to participate in entry reconciliation. You need to obtain a reconciliation […]
QUESTION: We have several entries for which we would like to make changes to the HTS classification used. The HTS changes would result in my company receiving money back from CBP. These entries have already liquidated and have had value reconciliation filed on them. The reconciliation entries have also liquidated. Do we have any options […]
QUESTION: Our company had been flagging entries for RECON when 301 kicked in last September with the intention of (obviously) updating the value. 301 occurred while in the process of assessing both first sale viability and a pricing restructure. We have determined the pricing restructure is not eligible for RECON as there was no agreement […]
QUESTION: We’ve identified a recurring issue with one of our suppliers and broker, where the invoice is listed in a not-USD currency and the broker has inconsistently done the currency conversion on the 7501. For any non-revenue entries, we’d just like to correct the value via value Reconciliation. Does anyone else use Recon to correct […]
QUESTION: Our company is in Recon and we are filing appropriately within the time frames. The next set of filings will greatly increase value over that declared at import. Is there a value increase percentage (eg. over 25 %; over 40 %; etc) uplift which will raise a red flag ? =========== Answers: Difficult to […]
QUESTION: As there is a CBP Recon Program for the USA, are there ones in Canada and Mexico? If so what they called. Also can an NRI, who imports into the USA participate in the Recon Program, or is it just for USA based importers. ============ Answers: Reconciliation is a US program. In Canada if […]
QUESTION: Per the ACE Reconciliation Prototype, value reconciliations are due within 21 months of the oldest entry summary flagged for and grouped on that reconciliation. My question is: 21 months from which date on the entry summary? Entry date? Import date? Entry Summary Date? Time Frames Reconciliations have due dates for filing, which are determined […]
QUESTION: Is there a percentage over the original imported value that when reported thru recon will raise red flags with CBP ? I looked in the Recon handbook and could not find any guidance. If the recon adjustment is 10 – 15 % I think not. If a recon adjustment is 70 – 80 % […]
QUESTION: The organization I work for uses transfer price adjustments (TPA) for related party transactions. When preparing for customs reconciliation filings, what are the questions that I should be asking our corporate tax group to get the TPA information required to complete the reconciliation filing? =================== ANSWERS: In my opinion, I would not ask them […]
