First Sale Valuation Qualification
A First Sale for Export Program can be an invaluable area to legally reduce the amount of customs duties and fees, and demonstrate the importance of a customs compliance department. The First Sale requirements are based on Court decisions, Department of Treasury guidance, and CBP Rulings covering a wide range of compliance topics including Incoterms, Valuation, Recordkeeping and Related Parties. Evolving supply chain and IT factors may also pose challenges needing evaluation before proceeding. Another challenge is that the U.S. is currently the only country to still use the First Sale for the entered value.
Each phase of a First Sale Program requires many decision points and considerations, where the best option may be different for each importer. Each importer will have its own unique compliance culture, customs resources and supply chain factors that will impact a First Sale Program. The presentation will discuss the options to evaluate at each phase of the process. Implementing a compliant program includes evaluating many factors including how much to review at each phase, how much to rely on external parties, especially for related party analysis, and factors to consider for communication with CBP.
Presenter: Tony Saranchak, Deleon Trade LLC