Reconciliation

Reconciliation

  • RECON ENTRY BY ENTRY

    QUESTION: We’re taking over reconciliation from another team. Recon has always been filed as aggregate which waives our ability to claim drawback whenever we export any of the imported finished goods.  We’d like to change and file entry by entry reconciliation to enable us to claim drawback where we can.  Is there a way to […]

  • QUESTION:

    We are filing Reconciliation on a US import from Canada, and discovered too late that the PSC we filed was not accepted. Data in ACE shows the wrong HTS and quantity and value are both lower than they should be. The Broker has advised that we cannot file Recon until the HTS is corrected in […]

  • RECON AND VOLUNTARY TENDER

    QUESTION: We are filing Reconciliation on a US import from Canada, and discovered too late that the PSC we filed was not accepted. Data in ACE shows the wrong HTS and quantity and value are both lower than they should be. The Broker has advised that we cannot file Recon until the HTS is corrected […]

  • TRANSFER PRICING AND RECON

    QUESTION: I have a question regarding Customs valuation. By way of background, my company is a wholly-owned U.S. subsidiary of a parent company in Denmark. The parent company sells products to us from a Maquiladora facility in Mexico for import into the U.S. We, the subsidiary, are the importer of record. We, in turn, sell […]

  • Value Variance in Reconciliation

    QUESTION: Our sister site in MX is considering transitioning to a maquila.  They are currently examining their value variance percentages.  On the average there is only a 1.1% variance between the original value declared and the actual value reconciled. But, if we dig down to a line level for  specific products, the variance can be […]

  • Reconciliation

    QUESTION: I’d like to ask the membership their opinion about doing reconciliation.  My company has a maquila in Mexico.  Almost all of the products that get sent to the US qualify for USMCA.  We use the “computed value” method for customs valuation because no “sale” is taking place. But the computed value is technically an […]

  • RECON LATE FILING MITIGATION

    Your Social Security Statement QUESTION: Does any member have experience and can provide advice with mitigating penalties for late file reconciliation entries?  ******************* Answers: Yes.  Once you actually file your recon, CBP’s late filing mitigated penalties kick in. CBP’s 2020 Reconciliation Guide provides (p. 52)( https://www.cbp.gov/document/guides/ace-reconciliation-external-guidance ): In the event that an importer receives a […]

  • RECON – PROTOTYPE OR PROGRAM

    QUESTION: Is Reconciliation still in prototype or is it a fully released program? %%%%%%%%%% ANSWERS: Reconciliation is still considered in prototype status.  The status as a “prototype” program has little bearing in the application of the program from a practical point of view. Section 637 of the Mod Act (1993) amended Section 484 of the […]

  • AGGREGATE VALUE RECON

    QUESTION: I have 2020 entries flagged for Value Reconciliation for a business unit (IOR) that stopped importing in 2020 and is in process of being shut down.  Due to the way our transfer pricing & limited risk distributor agreements are structured and the expenses associated with shutting down the business unit, our reconciled Customs value […]

  • Liquidation and Recon filing

    OT Fact Sheet: Origin Certification Requirements QUESTION: This just came in: The Court of International Trade will stop liquidation of unliquidated entries subject to the List 3 or 4A Section 301 China tariffs imported by the thousands of plaintiffs in the Section 301 litigation, a majority of judges on the three-judge CIT panel said in […]

  • VALUE RECONCILIATION SCENARIO

    OT Fact Sheet: Origin Certification Requirements QUESTION: This question relates to a Value Reconciliation where a downward pricing adjustment is insignificant. The Reconciliation External Guidance doc states that the full data must be transmitted even if there is no revenue impact. What if the change is insignificant, so .2% or .4%? Is there a de […]

  • VALUE RECON

    QUESTION: Our executive team posed the following questions regarding value reconciliation and hoping to get some guidance. Does the importer always have to submit a change if the value is not exact – in other words, is there a duty amount (under or over threshold) that could be considered a “No Change”? For example, if […]