Alliance Drawback Services takes full responsibility for the drawback process from the initial implementation of the program to the filing of drawback claims. The first step in the drawback process requires that we conduct a thorough evaluation to quantify the recovery potential and assess the resources required to prepare claims and manage the program. The following summarizes the services that we perform throughout the drawback process:
- Evaluate drawback potential for direct and "third party" drawback opportunities.
- Gather required drawback documentation and/or information from a client's forwarders and brokers. If possible, we prefer to gather the documents on-site to expedite the filing process.
- Perform drawback calculations and key required data elements into our specialized drawback system.
- Generate required Customs reports and forms, and file claims with Customs.
- Transmit portion of each claim electronically to Customs to expedite payment.
- Maintain documents to assist with record keeping requirements as outlined in 19 CFR 191.
- Secure or update Customs privileges (accelerated payment and waiver of prior notice) with U.S. Customs.
- Draft and submit the required manufacturing drawback ruling if required.
- Conduct annual compliance assessments.
- Accurate preparation of the client's drawback entries.
- Draft any needed ruling requests and apply for participation in Customs new "Informed Compliance" Program when available.
- Provide on-site audit support in the event of a Customs audit.
If the recovery potential justifies establishing a program, we will then conduct an on-site implementation of a client's drawback program with the following objectives:
Develop Program Procedures:
To ensure regulatory compliance, and to maintain the timely filing of drawback claims, we will develop comprehensive program procedures that address the following areas:
- Documents and data needed to prepare and file claims - To capture the needed documents, we typically employ a variety of methods including copying documents on-site, data downloads, and securing documents from a client's forwarders and brokers.
- Drawback record retention.
- General information related to the claimant's business practices and manufacturing processes.
- Frequency and objectives for periodic compliance reviews.
Review existing record retention - During the implementation visit we will review the types of records routinely required to substantiate claims during a Customs audit. While only a small portion of claimants will actually be audited, we prepare for the possibility of an audit from the inception of the program. As part of the implementation report, Alliance International will offer suggestions as to how to improve record retention procedures without creating an additional burden to the client.
Gather documents and information needed to prepare Customs applications - Alliance International will draft Customs applications for accelerated payment, waiver of prior notice, and draft a manufacturing ruling request if applicable. To prepare these applications, we will need to gather a variety of company information and sample documentation.
Understand client's business operations - As part of the implementation visit, we try to learn as much as possible regarding our client's specific business operations and its industry in general. This knowledge assists us in designing a compliant drawback program and can help us identify other potential drawback opportunities.
Instead of charging consulting fees for various functions in the process (the most common additional fees being those that cover the Customs application process as well as audit support costs) in addition to percentage of the recovery, Alliance International operates primarily on a contingency fee (a percentage of the total recoveries collected by the client). The contingency fee compensates Alliance for all the services described herein including implementation, claim filing, program management, and on-site audit representation, if required. We will not bill for services until our client receives its refund.
In some instances, we will bill for out-of-pocket travel required to administer the program. For example, if Alliance personnel need to copy import documents on site at a third party import vendor's facility, we would request prior written approval for the travel expenses. On-site audit support also would require reimbursement of travel expenses.
The average contingency fee ranges from 10 percent to 20 percent depending on the recovery level and resources required. The actual fee could be higher or lower based upon these factors. Following the completion of the program assessment process, Alliance will submit a specific fee proposal for consideration.