New Customs Publication Demands Independent Satisfaction of Customs Value Requirements
Client Alert | 1 min read | 05.31.07
Several weeks ago, U.S. Customs issued another in its series of Informed Compliance Publications for importers, this one concerning transfer pricing. We have included a link below.
There has always existed a tension between international transfer pricing principles under the customs laws (which seek to maximize import value) and under the income tax laws (which seek to minimize cost of goods sold), but for some time there was a tacit recognition by Customs that a tax compliant transfer price would not be challenged by it. The new Customs publication refutes that tacit recognition, and demands independent satisfaction of the customs value requirements. The Customs publication does acknowledge, however, that the same economic and financial analyses which led to a tax compliant transfer price might support a customs compliant transfer price, but that importers would at least have to perform a separate "reasonable care" inquiry under the customs laws and not just assume that the tax-driven transfer price is an acceptable customs value.
Contacts
Insights
Client Alert | 4 min read | 04.09.26
DOJ Establishes National Fraud Enforcement Division
On April 7, 2026, Acting Attorney General Todd Blanche issued a memorandum establishing the National Fraud Enforcement Division (NFED) within the U.S. Department of Justice (DOJ). This new division will be dedicated to the centralized, coordinated investigation and prosecution of fraud against taxpayer dollars and taxpayer-funded programs. AAG Blanche acknowledged that, while DOJ has a “storied history of combatting fraud,” DOJ has “never adopted a comprehensive and coordinated approach to investigating and prosecuting fraud against taxpayer dollars and tax-payer funded programs.” The NFED was created to close that gap with its core mission being to “zealously investigate and prosecute those who steal or fraudulently misuse taxpayer dollars.”
Client Alert | 2 min read | 04.09.26
OMB Issues New Policy on Federal IT Transparency and Acquisition Oversight
Client Alert | 3 min read | 04.09.26
Preserve It or Lose It: A Missing Jury Instruction Costs Columbia University $94M in Damages
Client Alert | 5 min read | 04.09.26
U.S. State Privacy Enforcement: Key Priorities and Practical Guidance From State Regulators

