Practice Areas

Customs and Foreign Trade

Ryan’s holistic approach to Customs and Foreign Trade cuts through the incredible complexity of global taxation on imports and exports. Our experts scrutinize every detail—from purchase order to payment—and deliver substantial tax savings that improve profitability and cash flow.

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Customs and Foreign Trade Services

U.S. Customs and Border Protection (CBP) collects an estimated $32 billion annually in duties paid on imported goods entering the country. CBP may also collect additional ad valorem fees such as Merchandise Processing Fees (MPF), Harbor Maintenance Tax (HMT), Anti-dumping (AD) and Countervailing Duties (CVD), and certain Internal Revenue Taxes (IRT). In addition, importers also may pay federal excise taxes directly to the Internal Revenue Service as a result of importation.

Ryan mitigates the negative impact these complex dynamics are having on your organization’s bottom line. Our approach to Customs and Foreign Trade consulting is innovative and unique. While we do specialize in the duty drawback and Foreign Trade Zone service areas, unlike a typical issue-based practice, we take a comprehensive approach to analyzing your business trade activity. We look at the whole picture of who you are as a global trader—as a direct importer or who buys imported products from others; and as an exporter, or as a supplier to customers, who in turn, sell products internationally. From purchase order to payment, we scrutinize every detail of your process. After thorough evaluation, we present a number of different strategies that will save you significant time and money.

Ryan’s Customs and Foreign Trade practice takes a comprehensive view of the current burden paid by our clients and provides a comprehensive suite of services focused on providing the greatest reduction in duties, taxes, and fees. As a matter of fact, we have a history of proven success providing clients substantial value and results in the areas of Duty Drawback, Foreign Trade Zones, Customs Classification and Valuation, First Sale for Export, and Legislative Relief. View these case studies below as proof of the value we can provide your organization.

Duty Drawback Case Study

Client Issue:

A major U.S. manufacturer and distributor of agricultural and construction equipment imports a high volume of dutiable component parts used both in manufacturing and as spare parts. The client also imports parts that are returned from foreign locations for repair, maintenance, or refurbishment. The imported parts are exported as either spare parts, repaired or refurbished parts, or as parts embedded in finished equipment from U.S. facilities. The client was aware they may qualify for duty drawback savings but did not understand the legal and administrative filing requirements nor did they possess the manpower to locate and provide the necessary data and documents to substantiate drawback claims.

Approach and Solution:

Ryan worked with the client stakeholders to gain an understanding of their entire supply chain in order to identify and obtain the maximum amount of refunds afforded to them while, at the same time, identified compliance issues and helped address them. By analyzing large electronic datasets along with pulling and reviewing historical client documentation, Ryan worked hand-in-hand with Customs and Border Protection Drawback Center Specialists to gain the necessary approvals to establish separate “unused” and “manufacturing” drawback programs and subsequently file retroactive electronic claims for past year's eligible export activity with accelerated payment privileges for both programs.

The Result:

The client has received significant retroactive savings through each duty drawback program and will continue to do so moving forward with Ryan’s assistance.  Additionally, the client now possesses a solid understanding of the duty drawback laws so that drawback may be considered on future supply chain decisions.

Foreign Trade Zones Case Study

Client Issue:

A major U.S. oilfield services company operates a large warehouse within the state of Texas where various types of very high-value oilfield equipment, components, and parts as well as specialized tubular goods, are stored and maintained. The stored equipment is used to service deepwater offshore drilling rig operations. The equipment may reside within the client warehouse for years before being removed for export to the deepwater rig.  The equipment was subject to extremely high ad valorem business personal property (BPP) taxation.  The Client contacted the local Ryan Complex Property Tax (CPT) team seeking advice on how it could minimize BPP taxation on equipment stored in its warehouse.

Approach and Solution:

Ryan CPT analyzed the client fact situation and identified a federal BPP tax exemption related to goods held for export in an active U.S. Foreign Trade Zone (FTZ) facility. CPT contacted the Ryan Customs and Foreign Trade practice team to confirm the federal exemption, as well as what steps needed to be taken to obtain FTZ status for the client facility and activation of the facility by the local Customs and Border Protection (CBP) port director within a six-month window in order to be in place prior to the next BPP tax assessment date. Ryan presented a proposal to establish and activate the client warehouse and laydown yard as an FTZ.  Upon client acceptance of the proposal, the CFT team prepared an FTZ application and obtained the sponsorship of the local Port Authority to present the application to the U.S. Foreign-Trade Zone Board for approval. The application included letters of support from the local tax jurisdictions, which Ryan obtained on behalf of the client. Once approved, Ryan CFT presented an activation application to CBP that met all the CBP compliance requirements, including an operations manual, security profile, and identification of “key” client warehouse site employees responsible for day-to-day FTZ compliance. During this time, Ryan also met with the client facility management team to gain an understanding of site operations and to create practical customized FTZ operating procedures tailored to the operating environment. Upon client acceptance of the procedures, Ryan provided FTZ general compliance, inventory control, and reporting training to corporate and site personnel. Ryan was able to obtain CBP activation prior to year-end in time for the client to take advantage of the federal BPP tax exemption.

The Result:

The client has received significant BPP annual savings with the assistance of both the Ryan CPT and CFT practices with minimum impact on client day-to-day operations.  Additionally, the client now possesses a solid understanding of the FTZ laws and regulations and has been able to avoid duties and fees on new equipment sourced from foreign suppliers and imported directly to the FTZ, as well as equipment, parts, or components returned to the FTZ from offshore rigs for maintenance or repair.  

Customs Classification and Valuation Case Study

Client Issue:

A U.S. marketer and distributor imports complex specialty chemical products into the United States; however, it lacks internal customs compliance expertise.  The client relies heavily upon its customs broker’s inexperienced entry agents for advice and counsel, which has led to the assessment of rate advances and penalties by U.S. Customs and Border Protection (CBP). 

Approach and Solution:

Ryan collaborated with the client and devised a procedure for not only furnishing the tariff classification and the rate of duty on new products but to also address the client’s other concerns, such as whether the goods are subject to anti-dumping or countervailing duties, determine whether Toxic Substances Control Act (TSCA) entry reporting is required, and advise on the eligibility of the products under free trade agreements and special trade programs.

The Result:

As a result of Ryan’s keen focus on duty minimization, the client has realized not only significant cost savings but a greater opportunity to compete with lower cost competitors.  The client has improved its compliance standing with CBP and now possesses a robust tariff database that could easily withstand the scrutiny of CBP during an audit.  

Ryan Expertise

The client service Ryan provides has exceeded our expectations, and we look forward to continuing our relationship for many years to come.
Greg Malerbi Senior Vice President and Treasurer client logos_clean-harbors

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