Question: Our company provides loaner equipment while we work on repairing an item that a customer has returned to us. The loaners are provided at no cost and no transfer of ownership takes place. In some scenarios, our customer (“Sold to”) is a US entity, but we ship to their customer (“Ship to”) outside of […]
Question: We have have received a purchase order from Mexico customer. We are requested to deliver shipment to consolidation point in Laredo Texas. It sits there until the forwarder is ready to export the goods to customer in Mexico. Since we don’t know when it will be exported we should not be exporter of record. […]
Question: I joined a new company and discovered that for the last 5 years a business unit has been reporting the wrong EIN/USPPI. After determining who is actually the USPPI, the business unit is in the right path. However, what about the 5 years of misreporting? Perhaps a disclosure? Does the company need to go […]
Question: My company has accepted a blanket PO for hardware that will mostly be shipping to US ship to locations. The PO is issued from our Customer’s US entity to our company’s US entity. There however will be a need to fulfill some hardware to the customer’s Canadian offices. Under regular circumstances, this is a […]
Question: At the request of Company B (US), Company A (US) needs to ship a warranty replacement to Company C (EU). In the original transaction Company A sold to Company B. The warranty replacement is being sent free of charge. Since Company A ships this at their cost, can they act as the USPPI? Or […]
Question: On a SLI, the USPPI address is the physical address of where the EIN is registered, correct? If the goods are physically in a different location than the USPPI, (within the US), what is the point (state) of origin? Answer 1: NOOOOO!!! The USPPI address MUST be per 30.6(1)(ii) – the address from which […]
Question: We are returning defective product to an international supplier without a US presence. A credit memo has been issued, so ownership has passed back to the supplier. We then put the onus on our supplier to prepare the documentation, which we assist by making sure it’s accurate. I need to know if I’m reading 15 […]
Question: Being new to the company I am finding out some odd transactions via an audit. First transaction. My company sends (not sold) medical devices and components to a USA kitting company. The USA kitting company than sends our goods to their kitting facility in Mexico. The USA kitting company exports and declares themselves as […]
QUESTION: We had an earlier request where we received input not able to act as USPPI. We took this seriously and have investigated, it is however a difficult regulation. I therefore have a couple of questions regarding exemptions for EEI registration. We have understand that a foreign entity not established in US, must not have […]
Question: In this scenario who is or can be the USPPI? Seller A sells FOB Port of Houston to Customer A (a US entity). Then Customer A (a US entity) sells FOB Port of Houston to their foreign entity . ========== Answers: Who is exporting? Sounds like Customer A. The audit trail for the […]
QUESTION: Transaction details: US Company A (reseller), purchases material from OEM in the US OEM ships material to Company A’s warehouse facility in Illinois US Company B issues a Purchase Order to Company A, from a US “Bill To” address and international “Ship To” address (foreign affiliate of US Company B – no sale involved) […]
QUESTION: Who is the USPPI in this scenario? The US entity (XZY Corp.) is owned in its entirety by its parent – XYZ International. XYZ International was set up as a foreign trade company for legal purposes/tax purposes/payroll purposes/state purposes but it doesn’t have any employees. Goods are made by XYZ Corp. and are then […]
