QUESTION: This is something brand new that has come up. While I do (not) see anything wrong with the transaction it is strange and something that I have never seen. This is a drop shipment in which all 3 entities are related. The first transaction is a purchase of finished goods (Not Dutiable) between MD […]
QUESTION: I have been working with the TP team to set up a process to capture any future adjustments. The first adjustment will come in March or April, 2020. Our TPs are out of whack and we need to bring them into alignment with normal pricing of unrelated transactions. However, these seem to be so […]
QUESTION: Scenario: Australian based company is importing to US using Foreign importer filer ID shipping to a fulfillment center (e-commerce model) . Can they declare as transaction sale value the cost of goods they paid to the manufacturer or do they need to declare sale value in the US (sale value to end customer)? ========== […]
QUESTION: Need some help figuring out whether transaction value or a “first sale” value applies for the following US import transaction: • Company A (US) purchases products from Company B (UK) at an FCA (Origin) price of USD $35.45 each. • Company B (UK) purchases products from Company C (TW) to fill the order at […]
QUESTION: We are looking to import some machines from Germany. Our purchase agreement with the vendor details the cost of the machine and our P.O. reflects that value but there is a second provision in the purchase agreement that advises that we must reimburse the vendor for the costs incurred for travel, hotel accommodations, food […]
QUESTION: I’ve read through a lot of the ICPA presentations and CBP rulings regarding US Customs valuation of used parts using fallback method. One thing I’d like to clarify…assuming that using some “percentage of new” value is acceptable (please assume this is already confirmed/verified), is it percentage of the new PRICE to that customer, or […]
QUESTION: I am pushing my VP to adopt a 4-way match process (purchase order, commercial invoice, declaration to CBP, accounts payable records) ensuring what we declared to CBP is what was outlined and ultimately paid in our AP records. My VP says he wants concrete evidence it’s a regulatory requirement and not just a “good […]
QUESTION: We are considering expanding our First Sale for Export (FSFE) program in light of the Section 301 tariffs and would like to do some benchmarking to see if other retails are doing the same. If your company participates in the First Sale program, do you handle within Trade Compliance department, work with your legal […]
QUESTION: I am pushing my VP to adopt a 4-way match process (purchase order, commercial invoice, declaration to CBP, accounts payable records) ensuring what we declared to CBP is what was outlined and ultimately paid in our AP records. My VP says he wants concrete evidence it’s a regulatory requirement and not just a “good […]
QUESTION: Historically we have had the price of appliances be hardware + software with one part number. Now hardware and software license pricing is to be separate (having their own part number and price). Should the value of the software license be included on the commercial invoice? (Note: ECCN of hardware is 5A002 due to […]
QUESTION: Facts: There is a single seller and a single related purchaser, so Acme Canada sells to Acme USA. There is a single part #123. Transaction value is used (i.e. transfer pricing policy has been deemed acceptable for Customs purposes). Scenario: Depending on which physical location the goods are shipped from, the transfer price / […]
QUESTION: I am new to the First Sale program. Can you tell me if a reconciliation afterwards to amend the value to the first cost is the only way to implement first sale? Or is it done that way only so it won’t disrupt the cargo flow? ========== Answers: Assuming you have fully vetted your […]
