trade support network ace concept paper june 4, 2002 millie gleason robert hamilton john durant
TRANSCRIPT
Trade Support NetworkACE Concept Paper
June 4, 2002Millie Gleason
Robert Hamilton
John Durant
Methods of Filing
Traditional Entry Summary– 10 Days – Electronic Payment
10 Days Monthly Periodic Payment Date
Importer Activity Summary Statement (IASS)– Monthly Filing– Electronic Periodic Payment
Periodic Payment System
Commissioner’s Mandate of Revenue Neutrality
1st-15th: Monies due on 22nd
16th-End of Month: Monies due on 7th
Netting Payments and Refunds
AD/CVD
ACE Will Allow Commerce to Transmit Dumping Orders and Liquidation Instructions and other AD/CVD Case Information Electronically
This Process Will Automatically Suspend All Line Items Identified Within an Order
Reconciliation Flag Whole Entry or Just Specific Line Item
Retroactive Flagging
Issues Include Current Elements as well as Other Elements not Affecting Admissibility
Accounts Will Be Able to View All Flagged Entries and Customs Figures
Reconciliation
If Line Item is Flagged for NAFTA, Reconciliation is the ONLY Method of Making Claim
Filers will Have 21 Months to Reconcile Outstanding Issues vs. 15 Currently
Off-Line Spreadsheet No Longer Necessary
Elimination of SILs/PEAs
ACE Will Allow Line-Item Corrections of Clerical Errors to be Made Electronically by the Filer Without Customs Involvement
This Will Eliminate Submission of Paper Documents and Quarterly Reporting Requirements
Extension/Liquidation
Unless Notified, Account May Assume That Liquidation Will Occur One Year from Date of Summary
Courtesy Notices of Liquidation Will Be Replaced By Account Portal Access
Paper Bulletin Notices Will No Longer Be Posted in Customhouse
Extension/Liquidation (Con’t)
ACE Will Perform Extension/Liquidation at Line Item and Summary Level (This Includes IASS and Reconciliation)
No Change Liquidation Under ACE Means That the Monies Deposited by the Account Were Found Acceptable at Date of Liquidation
Protests
Current Law Provides for 90 Days from Liquidation for Protest; One Year for Petition
Under ACE, a Six Month Period from Date of Liquidation to File All Protests/Petitions
AFRs Will Be Filed Electronically with Submission of Protest
Export of Merchandise
ACE Will Link to AES
Customs Favors a Simplified Drawback Program Based On a Consensus Proposed with the Trade that is MUTUALLY BENEFICIAL
Drawback Refunds Will be Issued by Periodic Statement
General Import Profile
24 Million Entries; $25 Billion 99% Electronic; 72% Paperless 460,000 Importers
– 39% Made a Single Entry– 75 % Made 1-9 Entries– 5% of Importers = 78% of Entries by Value
By Importer = Top 100 = 33%, Top 1000 = 59%, Top 3000 = 72%
IASS
IASS (Monthly Entry)
Legal Implications
Release #1 Release #2 Release #3
IASS Design Questions
What is the “Legal Entity”?– Is it 1 Monthly Summary?
or– Is it 3 Entries Grouped on a Monthly Basis (like
ABI Daily Statement)? When Do I Have a “Late Entry”? What is “Extended/Suspended”? What is “Liquidated”?
IASS Design Questions
Customs Currently Extends .7% of the Entries -- What are the “Monthly” Implications?
Customs Will Insist on No “Split” Legal Liability. There are Impacts For:
– Brokers
– Sureties
Proposed Solution
Need Capability for Line Item Extensions/Suspensions/Liquidation
How? In Appropriate Sections Where It Says “Entry” add “or Line Item”
Interest Implications
If IASS Must Be Revenue Neutral then Customs Must Know Detailed Release Information
BUT,
There Must Be a Simpler Way!
There Is!
1. Change the Law to “No Interest Due” on IASS
OR
2. Change to a Simpler Interest Law, e.g. Average Daily Balance or Mid-Point
Deemed Liquidation
ACE Will Liquidate Via “Deemed Liquidation”
Therefore, Your Date of Liquidation Can Be Date of Summary + One Year
Can Be Done if We Change Deemed Liq Law to Read “One Year from Date of Summary”
Other Major Benefit: Far Less Confusing!
Protest Proposal
We Believe Protest vs. 520(C) is Confusing and Needs to be Simplified
Customs Proposal: 1. Extend Current 90 Days Protest Period to 180 Days. 2. Trade Off is to Eliminate One Year 520(C) Provision 3. Customs Keeps Current 90 Day “501 Authority” 4. Customs Agrees That “Protest” Involves All Aspects of
the Customs “Transaction”
AW SHUCKS!
WHAT AN HONOR!!!
Questions/Comments/Concerns