Question: We’re considering using 9802.00.80 and were curious if anyone in the membership has some lessons learned/red flags/other advice they’d be willing to share. Answer 1: OK, here’s a quick one (I’m sure you will hear many more). Watch out that your overseas assembly doesn’t become a substantial transformation. Answered by: Lawrence Pilon – lpilon@rocktradelaw.comTitle: […]
Question: In place of an annual rebate from a supplier, they want to give us a lower base price for a period of time (until we meet the rebate amount), then they will go back to charging us the regular base rate. Is this acceptable under pricing and valuation regulations? Answer 1: Yes this is […]
Question: We signed an agreement with a partner whereby we pay them a service fee of $75,000 to evaluate the impact of our material on the immunogenicity of their vaccine candidates. The agreement is very spcific in that it states that we will provide them 4 mg of our material to carry out the “study”/research […]
Question: Valuation Scenario: US Company “X” (Seller) exports products to overseas distributors at an agreed sale price. In addition, distributors pay royalties to Company X based on their sales. At the time of export, only the sale price is known because royalties are paid quarterly. Scenario 1:Company X acts as the USPPI and files the […]
Question: We send plastic cards from US to Canada distributor under HTS # 4911.99 with no software loaded on them . The disti places these cards in retail outlets for end users to buy the cards who then go to a website and download the software. The question is about the value of the cards […]
Question: I am a Canadian company that sold something to a US Company for $50,000. Normally the $50K would be the transaction value declared by the IOR at the time of import, but in this case, we sold on DDP terms, which makes us the NRI (non-resident importer) in the US. Am I allowed to […]
Question: We shipped product to a Canadian vendor for additional work. That vendor paid brokerage and duties to Canadian Customs. They are now sending the item back and have included those Canadian brokerage and GST/HST fees on the commercial invoice as a separate line item. We do not believe we can deduct those costs – […]
Question: Hello ICPA Membership! Does anyone have experience with pharmaceutical profit sharing with overseas manufacturers and how it affects CBP valuation? I am looking into reconciliation, but I wanted to know what is most common for these types of arrangements as I understand it is common in pharma. Answer 1: I would work closely with […]
Question: I am new in the Aerospace Industry, and working on creating the Valuation Policy for defective/used parts. It seems other companies in this industry use the 10% of the Fair Market Value for “as removed” parts that will be shipped to an international repair shop. There is a 50% chance these parts will be […]
Question: Is there any regulation stating that a value cannot be changed on a commercial invoice? We recently sent out a replacement for a warranty item. On the commercial invoice it had our cost on it. I was asked to change the value to the original cost we sent it out on. Is this practice […]
Question: I’m working on a unique situation and could use some guidance. We export a unit packed in a large wooden crate for safe transport. The unit is first placed in metal packaging for protection, and this metal packaging is then put into a plastic crate with foam stuffing. We typically send about 10 of […]
Question: A manufacturing company leases its equipment abroad. The term of the lease is typically unknown at the time of export and there is no offer for the customer to purchase the equipment in the lease agreement. Further, the manufacturing company only leases the equipment; it does not sell. Ownership of the equipment is retained […]
