QUESTION: I’ve read through a lot of the ICPA presentations and CBP rulings regarding US Customs valuation of used parts using fallback method. One thing I’d like to clarify…assuming that using some “percentage of new” value is acceptable (please assume this is already confirmed/verified), is it percentage of the new PRICE to that customer, or […]
QUESTION: I am pushing my VP to adopt a 4-way match process (purchase order, commercial invoice, declaration to CBP, accounts payable records) ensuring what we declared to CBP is what was outlined and ultimately paid in our AP records. My VP says he wants concrete evidence it’s a regulatory requirement and not just a “good […]
QUESTION: We are considering expanding our First Sale for Export (FSFE) program in light of the Section 301 tariffs and would like to do some benchmarking to see if other retails are doing the same. If your company participates in the First Sale program, do you handle within Trade Compliance department, work with your legal […]
QUESTION: I am pushing my VP to adopt a 4-way match process (purchase order, commercial invoice, declaration to CBP, accounts payable records) ensuring what we declared to CBP is what was outlined and ultimately paid in our AP records. My VP says he wants concrete evidence it’s a regulatory requirement and not just a “good […]
QUESTION: Historically we have had the price of appliances be hardware + software with one part number. Now hardware and software license pricing is to be separate (having their own part number and price). Should the value of the software license be included on the commercial invoice? (Note: ECCN of hardware is 5A002 due to […]
QUESTION: Facts: There is a single seller and a single related purchaser, so Acme Canada sells to Acme USA. There is a single part #123. Transaction value is used (i.e. transfer pricing policy has been deemed acceptable for Customs purposes). Scenario: Depending on which physical location the goods are shipped from, the transfer price / […]
QUESTION: I am new to the First Sale program. Can you tell me if a reconciliation afterwards to amend the value to the first cost is the only way to implement first sale? Or is it done that way only so it won’t disrupt the cargo flow? ========== Answers: Assuming you have fully vetted your […]
QUESTION: I am new to the company I am working for and also new to the First Sale program. I understand in order to use FS the following needs to happen: 1. A bona fide sale between the middleman ( our China operation) and the manufacturer. 2. Evidence from the manufacturer that the merchandise was […]
QUESTION: I have a question relates to buying commission. I understand that it is not a dutiable assist. What is the responsibility on reporting the amount that we paid for the buying agent commission? How to report the amount? If the buying agent commission is not listed on a separate invoice, do you see a […]
QUESTION: Is it permissible from a Census and GATT standpoint to sell a bundled product and engineering install solution as one-line item on an invoice (not-broken out services)? Or must the company break out these local services on the invoice even if they are estimations? Some foreign customers prefer a one-line item price due to […]
QUESTION: Our salesperson sells an exchange for value $X +an expected core. This is exported as value $X. The Core is imported at $Y (based on x subtract the average repair). The core after a month has been identified as Beyond Economical Repair and is shipped to the customer as proof for an insurance claim. […]
QUESTION: Can anyone advise what needs to be indicated on the 7501 when a first sale transaction is used for entry? Is there a special flag or indicator or information that needs to appear on the 7501 other than just the first sale cost for EV? ========== Answers: Customs used to require an “F” flag […]
