Earlier this year, U.S. Customs and Border Protection (CBP) issued a headquarters ruling reiterating that importers need to take the country of origin, as well as whether the product might be subject to Sec. 301 or 232 duties into account when coming up with formulas to apportion assist values.  Have you looked at your assist apportionments lately?  If not, now may be a good time to do so.

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Mark J. Segrist
Partner, Advisory Committee
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