Recent US customs notice may help compliance with potentially conflicting transfer pricing requirements

June 13 2012

The US Customs and Border Protection (US CBP) published a Notice on May 16 revoking a Headquarters Ruling, HRL 54764 (November 8, 2001). The revocation should make it easier for companies importing products purchased from a related party to navigate the potentially conflicting rules and procedures for complying with US transfer pricing rules, while properly reporting the dutiable value of property imported from a related party.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

more across site & shared bottom lb ros

More from across our site

Indirect Tax

This month in indirect tax: US and India strike trade deal, tariffs reduced

Trump announced he will cut tariffs after India agreed to stop buying Russian oil; in other news, more than 300 delegates gathered at the OECD to discuss VAT fraud prevention

Sam Sholli, February 04 2026

Transfer Pricing

Experienced MAP jurisdictions should develop TP experts: OECD

Taxpayers should support the MAP process by sharing accurate information early on and maintaining open communication with the competent authorities, the OECD also said

Sam Sholli, February 03 2026

Direct Tax

KPMG launches tax AI programme, unveils Duke Energy as participant

The Fortune 150 energy multinational is among more than 12 companies participating in the initiative, which ‘helps tax teams put generative AI to work’

Tom Baker, February 03 2026

Direct Tax

Indian court reinforces physical presence as cornerstone of service PE

The ruling excludes vacation and business development days from service PE calculations and confirms virtual services from abroad don’t count, potentially reshaping compliance for multinationals

Karanjot Singh Khurana, February 03 2026

Direct Tax

Business process management and workflow automation diagram with

International tax outlook 2026: digitalisation, AI acceleration, and ongoing fragmentation

User-friendly digital tax filing systems, transformative AI deployment, and the continued proliferation of DSTs will define 2026, writes Ascoria’s Neil Kelley

Neil Kelley, February 02 2026

Direct Tax

HMRC engagement over R&D claims has ‘incrementally improved’: ForrestBrown advisers

Case workers are ‘still not great’ but are making fewer enquiries, making the right decision more often and are more open to calls, ITR has heard

Sam Sholli, February 02 2026

Direct Tax

A taxing week: Firms’ archaic paternity leave should be consigned to history

There is a shocking discrepancy between professional services firms’ parental leave packages. Those that fail to get with the times risk losing out in the war for talent

Tom Baker, January 30 2026

Direct Tax

Partners greenlight Winston & Strawn-Taylor Wessing merger

Winston Taylor is expected to launch in May 2026 with more than 1,400 lawyers across the US, UK, Europe, Latin America and the Middle East

Noemi Distefano, January 30 2026

Direct Tax

This week in tax: Donald Trump and sons sue IRS and US Treasury for $10bn

They are alleging that leaked tax information ‘unfairly tarnished’ their business operations; in other news, Davis Polk and Eversheds Sutherland made key tax hires

Sam Sholli, January 30 2026

Direct Tax

KPMG UK partners paid more than EY and PwC counterparts

Overall revenues for the combined UK and Swiss firm inched up 2% to £3.6 billion despite a ‘challenging market’

Sam Sholli, January 29 2026