Bruce Leeds, Author at Braumiller Consulting Group

What is the “First Sale” Rule and How Does it Affect Me?

February 5, 2024

The First Sale Rule applies in circumstances such as the example above. A US company places an order with a middleman in the US. The middleman in turn subcontracts to a foreign supplier. The supplier then ships the product either to the middleman or to the original US company that placed the order, meaning either could be the importer of record. The entered value could be the amount on the original purchase order or the price paid by the middleman to the foreign supplier.

Challenges Ahead! – Requesting to be Excluded From the Xinjiang Exclusions

November 10, 2023

In April of this year U.S. Customs & Border Protection (CBP) issued Headquarters Ruling H330077. The ruling was in response to a protest filed by an importer that had a shipment of wearing apparel excluded from entry under a Withhold Release Order (WRO) at the port of Newark, NJ. The wearing apparel was processed from cotton produced in India, made into yarn and fabric in China, and converted to wearing apparel in Cambodia. None of the parties to the transaction were located in the Xinjiang Region of China.

Hot Topics In International Trade: Customs Broker Modernization Regulations 19 CFR 111

November 3, 2023

Bruce Leeds discusses the changing landscape for customs brokers amid changes recommended by COAC (Commercial Customs Advisory Committee) which is an advisory committee to U.S. customs. The result are changes to modernize regulations through an overhaul of part 111 of the customs the regulations, including responsible supervision and control.

Customs Brokers: Giving Credit to Accreditors

August 7, 2023

U.S. Customs & Border Protection (CBP) published the Final Rule on continuing education for individual customs broker license holders in the Federal Register on June 23, 2023. This Final Rule made several changes to Part 111 of the Customs Regulations and imposed a continuing education requirement on individual license holders.

Driving You MAD – Customs Issues in Mergers Acquisitions & Divestitures

June 6, 2023

When one company buys another there are typically two ways the purchased company will be treated: (1) It will be incorporated into the parent company and will no longer exist as a separate entity. (2) It will become a separately incorporated subsidiary of the parent company and retain its IRS number.

Revisions and updates to the International Traffic in Arms Regulations (ITAR)

Hot (or at least warm) Off the Press: Updates & Revisions to the ITAR

February 6, 2023

The Directorate of Defense Trade Controls (DDTC) is continuing its project to revise and update the International Traffic in Arms Regulations (ITAR). Some of the changes are editorial and some are substantive. If you are affected by the ITAR or think you might be, you will need to stay on top of the changes because some (or all) may affect you.

What Have They Done to the ITAR? – Revisions and Reorganization Underway

October 10, 2022

Joe Compliance has an export control issue involving definition of some of the terms being used. Joe goes to the website of the Directorate of Defense Trade Controls (pmddtc.state.gov) and clicks on “Review the ITAR.” He opens Part 120 where the definitions are found.

DDTC is Open to Open General Licenses

August 22, 2022

Some may be familiar with Open General Licenses (OGLs) used in the United Kingdom and some other countries. They allow export of dual-use, strategic and other controlled articles to specific destinations under certain conditions.

In the Middle of Changing the MID CBP Proposal for Global Business Identifier

December 5, 2021

In a Federal Register Notice on Oct. 6, 2021, U.S. Customs and Border Protection published a 60-Day Notice and request for comments for a Global Business Identifier (GBI) Evaluative Proof of Concept (EPoC).

Continuing the Proposal for Customs Broker Continuing Education

October 6, 2021

On Oct. 28, 2020, U.S. Customs and Border Protection (CBP) published an Advance Notice of Proposed Rulemaking on continuing education for individually licensed customs brokers. After receiving comments and feedback from the trade, CBP published a Notice of Proposed Rulemaking (NPRM) on this proposal on Sept. 10, 2021.

Bruce Leeds

Bruce Leeds

What is the “First Sale” Rule and How Does it Affect Me?

Challenges Ahead! – Requesting to be Excluded From the Xinjiang Exclusions

Hot Topics In International Trade: Customs Broker Modernization Regulations 19 CFR 111

Customs Brokers: Giving Credit to Accreditors

Driving You MAD – Customs Issues in Mergers Acquisitions & Divestitures

Hot (or at least warm) Off the Press: Updates & Revisions to the ITAR

DDTC is Open to Open General Licenses

In the Middle of Changing the MID CBP Proposal for Global Business Identifier

Continuing the Proposal for Customs Broker Continuing Education

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