What about IRC section 482 related-party imports?
Quick answer
Related-party imports under IRC section 482 have additional customs valuation considerations that affect CAPE eligibility. Tariffi's analysis engine flags related-party entries for special handling, and the licensed broker partner applies enhanced review. Enterprise engagements include coordination with your transfer-pricing advisors if needed.
Detailed Answer
Related-party transactions (imports between affiliated entities) require special attention in the CAPE context because of customs valuation rules and IRS transfer-pricing scrutiny.
Why related-party imports are different:
Under 19 CFR § 152 (customs valuation), CBP scrutinizes the declared value of imported goods when the buyer and seller are related parties. If the transaction value is influenced by the relationship, CBP may adjust the appraised value — which affects the duty amount and, by extension, the refund calculation.
IRC § 482 overlap:
The IRS's transfer-pricing rules under IRC § 482 require that related-party transactions be priced at arm's length. If your company has a transfer-pricing agreement (APA) or a Customs-IRS information sharing arrangement, the customs value of your imports may differ from the commercial invoice price.
How Tariffi handles this:
- Automatic flagging. Our ES-003 analysis identifies entries where the relationship between the importer and the foreign supplier may indicate a related-party transaction (based on IOR, filer code, and country-of-origin patterns).
- Enhanced broker review. Flagged entries go through additional review by the licensed broker partner, who verifies that the declared values are consistent with customs valuation requirements.
- Transfer-pricing coordination. For enterprise engagements, Tariffi coordinates with your transfer-pricing advisors (or Big 4 team) to ensure CAPE declarations are consistent with your existing TP documentation.
- Conservative filing. When customs valuation is uncertain, the broker may exclude specific entries from the initial CAPE filing pending valuation clarification — protecting both you and the broker from post-refund audit risk.
Your transfer-pricing team should be involved if your company has significant related-party import volumes. Contact enterprise@tariffi.io to discuss your specific situation.
Related Questions
Do you work with Big 4 advisors?
Yes. Tariffi's enterprise engagement structure accommodates co-advisory arrangements where your existing Big 4 tax or trade team owns the workpaper review. A licensed customs broker partner transmits to CBP under their own license per 19 CFR Part 111. The engagement letter accommodates a side arrangement with your advisor.
What's different about enterprise pricing?
Enterprise importers ($5M+ duty paid) receive custom-priced contingency below the standard 10/15/25% tiers, a co-advisory engagement structure that accommodates existing tax or trade counsel, and a dedicated underwriter. Volume-based fee negotiation starts at the first conversation. Contact enterprise@tariffi.io.
How do you handle procurement diligence?
Tariffi provides a complete diligence package under NDA: broker-partnership regulatory evidence (19 CFR Part 111, CBP Rulings HQ H326926 and H350722), FASB ASC 450-30 contingent-recovery memo template, engagement letter redline, security posture documentation (AES-256, TLS 1.2+, 7-year retention), and reference contacts from comparable engagements.
What happens if CBP denies my claim?
If CBP denies any entry in your CAPE declaration, you owe nothing on the denied portion. Your broker partner (Filer of Record) responds to any CBP Form 28 or Form 29 within the scope of the LPOA at no additional charge. For entries worth contesting, the broker may file a further protest or recommend CIT action.
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