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 […]
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 […]
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 […]
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 […]
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 […]
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 […]
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 […]
QUESTION: Wondering if anyone else in the industry does value reconciliation? If so, do you do an audit on your reconciliation? What are some of the important points you would recommend to cover in a reconciliation audit? ============= Answers: Just like any other entry we audit that the data reported was accurate and defensible through sufficient […]
QUESTION: After doing a deep dive, I have discovered that a past years’ recons were filed as no-change, when they should have had the value adjusted up (meaning more duty owed, mpf, hmf, etc..) 8 months worth. Is filing a PD the best way to correct this with CBP? (including submitting payment for the additional […]
QUESTION: We have many PSCs and protests pending, mostly for 301 refunds, and we will be submitting our value reconciliation this summer. I am concerned about trying to reconcile an entry while a PSC / protest is occurring simultaneously. What are your thoughts? %%%%%%%%%%% ANSWERS: On you open PSC’s and Protest, It is my understanding […]
QUESTION: Have a question about CBP’s Reconciliation Program (Recon). The Recon is available to any importer (IOR). Is the Recon program available to a Non-Resident Importer (NRI) who imports using a Customs assigned number? Also, does Canada and Mexico have a similar Recon Program? What about other countries having a Recon program? ************** Answers: Yes, […]
QUESTION: My Company filed Value recon in Aug 2019 for year ending 2018 which included commodities that had the additional 301 China tariff duty added (25%). Now our products fall under the Product exclusions. Does anyone know if there is a way to file an adjustment against the assist value added on the recon entry? […]
