Valuation

Valuation

  • First Sale program – similar programs in other countries?

    QUESTION: Does anyone in the membership know if other countries have duty saving programs in place for multi-tiered transactions similar to the First Sale program in the United States? Specifically looking for countries like China, India & Saudi Arabia, but would be interested to know if other countries have a program as well. ========== Answers: […]

  • QUESTION ON SET VALUE ALLOCATION

    QUESTION: Can the membership help explain how sets are valued for customs purposes. Example: 1) We are importing Bed Sheet sets. Each set contains 2 pillow cases, 1 Flat sheet, 1 Fitted Sheet. Each component has its own tariff code and must be declared separately on the entry. We receive a commercial invoice where the […]

  • Valuation – related parties

    QUESTION: Our US entity is purchasing materials from a third party supplier, cutting to size, then re-selling to a joint venture partner for the same price that they originally paid to the supplier. They are not adding any mark up or charging for the added labor. I have expressed concern that this does not follow […]

  • Additions to value and 301 duties

    QUESTION: Our end customer in the US has offered to “split” the extra costs of the 301 duties on goods imported from China with us. Is this an addition to Customs value? Or would it only be an addition to Customs value if it was the Chinese supplier offering, and it’s no problem if it’s […]

  • Transaction Value Related Party Drop Shipment

    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 […]

  • Transfer Price (TP) adjustments – large swings

    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 […]

  • E-COMMERCE VALUATION SCENARIO

    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)? ========== […]

  • First Sale or Transaction Value

    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 […]

  • Valuation question

    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 […]

  • FALLBACK METHOD FOR USED PARTS

    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 […]

  • IMPORT VALUATION TESTING

    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 […]

  • FIRST SALE PROCESS INITATION

    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 […]