Tag: Protest
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Section 232 duty refund pathways. Exclusion approvals, scope rulings, protests, retroactive recovery options.
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Section 301 duty refund and recovery options. Exclusion approvals, drawback, protest filings.
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Introduction: Compliance Is Not the Same as Oversight There is a persistent misconception in the U.S. importing community that having a customs broker handle entry filings is equivalent to having a compliance program. It is not. Most U.S. importers are not willfully non-compliant. They are, however, operating without meaningful oversight of the customs processes executed…
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When to file drawback vs refund (CAPE, protest, PSC). Decision matrix by entry type and import circumstances.
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Voluntary tender vs prior disclosure for compliance gap remediation. Different pathways, different penalty implications.
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IEEPA Tariffs: The Foundation and What Importers Paid The International Emergency Economic Powers Act (IEEPA) grants the President authority to impose tariffs and trade restrictions during periods of national emergency. In recent years, IEEPA has been invoked multiple times to implement tariffs on goods from various countries, affecting billions of dollars in imports and impacting…
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The ACE System Constraint: Why CBP Rejects Protest Claim Submissions CBP’s rejection of Post-Summary Correction (PSC) submissions for IEEPA-affected entries traces directly to Automated Commercial Environment (ACE) system limitations. The ACE system was not configured to accept or process entry submissions that remove IEEPA tariff components from the duty calculation. This is not a policy…
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The Supreme Court Settled One Question; The CIT Must Answer Others The Supreme Court’s decision on tariff refunds established a foundational principle: importers are owed refunds for duties collected under the International Emergency Economic Powers Act (IEEPA). However, settling the legal principle of refund eligibility does not resolve the practical complexities of execution. The Court…
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Customs broker engagement. Engagement letter, POA scope, fee structure, post-entry authorities, reporting requirements.
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Tariff classification services pillar. Classification opinions, binding rulings, audit defense, ongoing classification programs.