Toy balloon tariff classification: functional heading prevails over residual rubber and festive article headings, supporting penalties for deliberate ...
Customs valuation using comparable contemporaneous imports can displace declared value, while missing speaking orders require pursuit before competent...
Foreign customs declarations and importer admissions established undervaluation, supporting sequential value redetermination, differential duty, and m...
Customs seizure safeguards prevent detention-based limitation avoidance and invalidate provisional release conditions for imported vehicles under an i...
Corporate guarantee commission was allocated only in part where the guarantee to the foreign associated enterprise's lenders was jointly furnished by the assessee and its subsidiary; on that basis, only 0.25% was attributable to the assessee. Interest disallowance on borrowed capital was not sustained for non-interest-bearing advances to AAIPL because the advances were made in the course of the real estate business and the decision to waive interest was commercially expedient to protect business interests and principal exposure. The same commercial expediency principle applied to advances to SCA LLP after the assessee became the majority partner with management control, making the funding commercially driven and not a basis for disallowing corresponding interest.
Corporate guarantee commission was allocated only in part where the guarantee to the foreign associated enterprise's lenders was jointly furnished by the assessee and its subsidiary; on that basis, only 0.25% was attributable to the assessee. Interest disallowance on borrowed capital was not sustained for non-interest-bearing advances to AAIPL because the advances were made in the course of the real estate business and the decision to waive interest was commercially expedient to protect business interests and principal exposure. The same commercial expediency principle applied to advances to SCA LLP after the assessee became the majority partner with management control, making the funding commercially driven and not a basis for disallowing corresponding interest.
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