Question: For considering the definition of substantial transformation, it states a change in name, character or use. Could anyone comment on an example of a change in name and change in character? *************** ANSWERS: Here is an example: Raw wool from a sheep becomes yarn. Yarn becomes sweater. *************** Not sure what you are looking […]
Question: What are the views of the members regarding using ISO codes to display as the country of origin on either the documentation or marking of the article? There is a presentation in the ICPA library which says that ISO codes should not be used. ========== Answers: This is a yes and no answer. […]
Question: We used to have a corporate position that managed all reg/compliance updates issued by CBP at the beginning of each year. That position was recently eliminated. Are these changes readily available? Or do we need to sign up for it or request a report. ========== Answers: The CBP regulations are updated each year in […]
Question: We are facing a dilemma that hopefully others in the membership are facing related to the US sanctions against Russia. We are a US company and we license software to customers including customers in Russia. A few of our Russian customers are listed in OFAC’s Sectoral Sanctions Identifications List. Our software is not caught […]
Question: We recently had an inquiry to supply parts for a distributor in Russia. The parts would be sold to them and then inventoried and sold at a later date. The company themselves check out ok when I screened them against all the new sanctions. I’d like to investigate the best way to ensure that […]
Question: My question concerns the license value to be used in AES. I have asked a number of colleagues and I get different opinions. Let’s assume we have an export license for Product X: When we applied for the license, the unit value we used was $2,000. Six months later we have a sale at […]
Question: Good day ICPA Members, I was hoping some of you, who use the west coast (LA/LBC) ocean ports, could share your current logistics situation with me. We have a fair amount of ocean volume coming through the west coast and have for the last 2-3 weeks seen our turn time for CFS availability climb […]
Question: We are required to use one of the express carriers for all shipments that we pay for when possible. This is a nightmare for import compliance. We now require the carrier to contact us for instruction for EVERY import shipment so that we can provide proper instruction. Most shipments are items coming in from […]
Question: Does anyone have a template letter to send to distributors to remind them of US export regulations and restrictions on exporting to sanctioned parties? ========== Addl Answer: I have seen many such letters/ contract provisions and have drafted a few of them myself for clients. Most of the template documents that I have seen […]
Question: Our tax department self-assesses and accrues state use tax on purchase orders placed on vendors for material not included in the Cost of Goods Sold (COGS). Is this state use tax considered part of the price paid or payable? ========== Addl Answers: It is not clear, why an importer would ever be paying use […]
Question: Our affiliate in Mexico is planning on making direct purchase of fashion accessories from a U.S. vendor. Terms will be FCA U.S. port and they want the terms to be FCA Miami, FL, the location of our Distribution Center. The intention is then to consolidate these goods with the goods coming out of the […]
Question: Our tax department self-assesses and accrues state use tax on purchase orders placed on vendors for material not included in the Cost of Goods Sold (COGS). Is this state use tax considered part of the price paid or payable? ========== yes
