• Correct value to be declared

    QUESTION: I have a question regarding what is the correct value to be declared on an import. Scenario- domestic company issues a p.o. to us (USA company), we issue a p.o. to our manufacturer in China. They ship the goods to the USA, to our clients door directly. Entry made under our name, for we […]

  • Standard cost breakdown requested during customs valuation audit

    QUESTION: We are undergoing a Customs Audit of related party transactions. We are a US company. the Customs authority is outside the US and in the country of a related entity. The auditors asked for the detailed costs that comprise our full standard cost. Our Finance team is reluctant to provide this level of detail. […]

  • First Sale Program / Consolidation program

    QUESTION: We currently participate in the First Sale Program. All of our vendors (that are part of our FS program) are from Asia and our company is now looking to implement a consolidation center to build full containers. The goods may be stored for a few days or a few months. My advise was as […]

  • First Sale program – similar programs in other countries?

    QUESTION: Does anyone in the membership know if other countries have duty saving programs in place for multi-tiered transactions similar to the First Sale program in the United States? Specifically looking for countries like China, India & Saudi Arabia, but would be interested to know if other countries have a program as well. ========== Answers: […]

  • QUESTION ON SET VALUE ALLOCATION

    QUESTION: Can the membership help explain how sets are valued for customs purposes. Example: 1) We are importing Bed Sheet sets. Each set contains 2 pillow cases, 1 Flat sheet, 1 Fitted Sheet. Each component has its own tariff code and must be declared separately on the entry. We receive a commercial invoice where the […]

  • Valuation – related parties

    QUESTION: Our US entity is purchasing materials from a third party supplier, cutting to size, then re-selling to a joint venture partner for the same price that they originally paid to the supplier. They are not adding any mark up or charging for the added labor. I have expressed concern that this does not follow […]

  • Additions to value and 301 duties

    QUESTION: Our end customer in the US has offered to “split” the extra costs of the 301 duties on goods imported from China with us. Is this an addition to Customs value? Or would it only be an addition to Customs value if it was the Chinese supplier offering, and it’s no problem if it’s […]

  • Transaction Value Related Party Drop Shipment

    QUESTION: This is something brand new that has come up. While I do (not) see anything wrong with the transaction it is strange and something that I have never seen. This is a drop shipment in which all 3 entities are related. The first transaction is a purchase of finished goods (Not Dutiable) between MD […]

  • Transfer Price (TP) adjustments – large swings

    QUESTION: I have been working with the TP team to set up a process to capture any future adjustments. The first adjustment will come in March or April, 2020. Our TPs are out of whack and we need to bring them into alignment with normal pricing of unrelated transactions. However, these seem to be so […]

  • E-COMMERCE VALUATION SCENARIO

    QUESTION: Scenario: Australian based company is importing to US using Foreign importer filer ID shipping to a fulfillment center (e-commerce model) . Can they declare as transaction sale value the cost of goods they paid to the manufacturer or do they need to declare sale value in the US (sale value to end customer)? ========== […]

  • First Sale or Transaction Value

    QUESTION: Need some help figuring out whether transaction value or a “first sale” value applies for the following US import transaction: • Company A (US) purchases products from Company B (UK) at an FCA (Origin) price of USD $35.45 each. • Company B (UK) purchases products from Company C (TW) to fill the order at […]

  • Valuation question

    QUESTION: We are looking to import some machines from Germany. Our purchase agreement with the vendor details the cost of the machine and our P.O. reflects that value but there is a second provision in the purchase agreement that advises that we must reimburse the vendor for the costs incurred for travel, hotel accommodations, food […]