How to Survive a CBP Watch Audit and Increase Duty Savings and Compliance Along the Way
Webinar: 1 CCS Credit
The watch provisions within the Harmonized Tariff Schedule are among the most challenging due to the multiple breakouts requiring importers to classify and appraise at a component as opposed to a product level. In many cases, U.S. Customs and Border Protection has questioned and challenged the entry declarations of unsuspecting watch importers, which can result in liability for years of back duties and even penalties. This webinar will examine how to best address CBP’s watch inquiries and audits and to identify opportunities to reduce duty payments.
- Classification: Finding favorable watch construction provisions to avoid China retaliatory or other higher duties
- Value apportionment: Advocating for component appraisement based on your documentation and data instead of third-party data
- Compliance: Establishing reasonable care to avoid retroactive duties and penalties
- Duty savings: Leveraging first sale, trade preferences, and other programs
- Marking and origin: Using the substantial transformation test to your advantage
- Trademarks: Meeting the elusive Swiss certification standard
Lenny Feldman is a Senior Member of Sandler, Travis & Rosenberg, P.A., and serves on the firm's Operating Committee. He served as a senior attorney at U.S. Customs’ Office of Regulations and Rulings from 1991 to 2000, where he issued hundreds of decisions and trained agency officials on customs laws and regulations relating to classification, origin, trade preference, valuation, and enforcement. Today he serves as counsel to numerous corporate officials on global compliance and enforcement issues and serves as co-chair of the Commercial Customs Operations Advisory Committee.
Sherri Moslowitz is an auditor for Sandler, Travis & Rosenberg, P.A., resident in the New York office. She is directly involved with the coordination and conduct of quick response importer audits and focused assessment reviews performed by CBP as well as the preparation and submission of prior disclosures. She also assists clients in matters involving valuation (e.g., related party transfer pricing issues, entry reconciliation programs, and first sale transactions), classification, foreign-trade zone compliance, duty preferences and free trade agreements, and other customs-related compliance issues. She began her career as an auditor with the U.S. Customs Service’s New York Regulatory Audit Division and later served as an assistant controller with a manufacturing and import company.