On Tuesday, September 11th, USA-ITA and Associate Member Sandler, Travis & Rosenberg hosted a webinar on first sale. The presentation was led by STR’s David Cohen, who previously worked in the valuation branch of the Office of Regulations & Rulings and has counseled clients on customs law, and specifically customs valuation, for 13 years.
Cohen’s presentation focused on two themes. He said importers who want to utilize first sale need to both:
- 1.Stay informed, particularly of the historic context of first sale to better understand it’s role in government and private sector decisions; and,
- 2.Be prepared, by structuring new first sale transactions (and auditing existing first sale transactions) to ensure compliance.
Although U.S. Customs & Border Protection has been resistant to first sale, it can be a valuable tool in wringing out costs from supply chains if you know how to do it. After providing a history of first sale, Cohen gave importers tips on how to qualify new transactions and validate existing transactions.
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