Valuation

QUESTION: A customer returned product to our Chinese entity because it was defective. Due to currency control restrictions and difficulty getting money out of China the China entity is considering to reimburse the customer via a discount in the amount of the defective goods on the next commercial invoice. Is the transaction value on the […]

QUESTION: Will any of the members have experience in proper customs valuation on Inventory Stock Transfer? We are a Canadian company that will be transferring inventories to a related-party Warehouse in the USA for future sales order fulfillment. When the goods are being transfer in the US, we will Customs duty pay for these inventories. […]

QUESTION: The company I work for is considering to forego retrospective transfer price adjustments and just move forward with “prospective” transfer price adjustments. The way the tax team explained it to me is that they will capture any profitability issues in the true up “next year”. They advise that this should resolve any need to […]

QUESTION: We have a customer who wants to prepay for shipments as a way to hedge against currency fluctuations. They would send a Pro Forma Invoice with an amount and a few Part Numbers that they buy from us, but not necessarily the PNs they will buy from us on the next order. They will […]

QUESTION: We are sourcing and shipping materials to a collaborator in the EU for testing as part of a project. We issue our proforma invoices using the actual values paid for the materials we are sending, we are not selling the materials to them. We have just found out that the recipient is adjusting the […]

QUESTION: I recently spoke with the tax and finance team about how they set transfer prices and what is included in the calculation. When we started speaking about TP I advised them that duty would be assessed on the entered value which is the TP (assuming Customs accepts TP as the TV).  They responded, we […]

QUESTION: We have determined that our transfer pricing model with our related party supplier is valid for use under Customs transaction value methodology. We are not in recon despite my recommendations in previous years. I just learned that my company will be receiving credits (adjustments to unit value) from our related party supplier for numerous […]

QUESTION: My company is revamping its clinical valuation practices and I’m wondering if anyone has insight as to methodologies for valuing commercially approved drugs to be used in the clinical space for reindications or as comparators.  It is my understanding that since there is no price paid or payable, one would seek to use the […]

QUESTION: Would any members have a copy of TD 85-124 to share ? Can find anything but rulings referencing the decision. ========== Answer: I do not have a copy of TD 85-124 , however, I do have info from a Senior Import Specialist at the Electronics CEE- Enforcement Division in Memphis on this matter, see […]

QUESTION: Currently our Canadian company is sourcing goods from China and re-selling to our US Company. Transfer pricing case is in place due to related party transaction. We paid duty on the highest price of goods when sending product to the U.S.  My questions: If our Canadian company  imports directly to the US as an […]

QUESTION: Does anyone in the membership have any information or resources on the mechanism of filing a transfer price adjustment with CBP? I have searched and found various resources regarding the methods and requirements therein, but nothing on the actual mechanism. I also asked our broker if they were familiar with the process and they […]