U.S. Customs issues revocation of ban on retroactive adjustments to transfer pricing - Opening the door for routine duty refunds

Tax Insights ()

On May 30, 2012, U.S. Customs and Border Protection ("CBP") issued the long awaited ruling definitively revoking Headquarters Ruling Letter ("HRL") 547654 which imposed a limitation on the use of "Transaction Value" in related party transactions subject to post-importation adjustments. This ruling has many transfer pricing implications.