Compliance Self-Assessments

As an outgrowth of our involvement in international trade cases, ITR assists importers and their counsel in conducting U.S. Customs and Border Protection (Customs) compliance self-assessments. Given the increased burden on importers to exercise "reasonable care" in entering, classifying and valuing merchandise, prudent importers attempt to identify and correct problem areas prior to a Customs compliance audit thus preventing reporting errors and reducing potential penalties.

Our consultants, including CPAs knowledgeable in auditing techniques and systems analysts/programmers experienced in statistical analysis of large databases, assist in conducting self-assessments through the:

• Review of Customs compliance procedures and internal controls.
• Reconciliation of total entry value to payments to foreign vendors.
• Review of randomly selected sample entries for adherence to Custom's rules and regulations.

Because ITR works under the guidance of counsel, its work can be covered under attorney-client privilege. If the self-assessment uncovers problems in the importing process, this privilege can protect clients until the problems are corrected and the law firm files a prior disclosure, thus reducing the likelihood of penalties.

Compliance Audits

If Customs does conduct a compliance audit, ITR assists importers and their counsel during all phases of the process, including:

• Reviewing the company's accounting and information systems and internal controls.
• Reviewing and preparing detailed documentation supporting sample transaction entries.
• Reconciling total entry value to payments to foreign vendors.
• Actively participating in the audit.
• Providing post-audit follow up.

Computed Value

If an importer bases the valuation of its merchandise on computed value, our CPAs assist importers and their counsel in developing the appropriate reporting methodology. Through careful analysis and review of the company's financial and cost accounting systems, ITR helps ensure the computed value amounts:

• Trace to supporting accounting documents.
• Reconcile to the income statement.
• Include all dutiable costs and reportable assists.

ITR can also develop written procedures for company accounting personnel to follow to prepare the computed value annually.