Accounting for Tariffs (#374)
/Tariff Definitions
First of all, what is a tariff? It’s a tax that’s imposed on imports. There are two types of tariffs. The most common is the ad valorem tariff, which is a percentage of the value of the imported goods. There’s also the specific tariff, which is a fixed fee that’s based on a measurable unit, such as $10 per ton imported.
And one other definition. A tariff is the rate charged on imported goods, while a duty is the amount actually paid. For example, a tariff on something might be 20 percent, while the associated duty that’s paid turns out to be $120.
The Process for Paying a Duty
Next, what is the process for calculating and paying a duty? The importer or their customs broker classifies the goods using the Harmonized Tariff Schedule of the United States, which assigns a 10-digit code to determine the correct tariff rate. And by the way, the Harmonized Tariff Schedule is kind of large. It has about 17,000 tariff classifications. Tariffs can vary a lot by classification, so importers are routinely trying to change the classifications of imported goods to reduce the amount that they pay.
Moving on, the importer has 15 days from the arrival of the goods at a U.S. port to file entry documents with the U.S. Customs and Border Protection Agency. And, because that name is too bloody long, I’m just going to refer to it as U.S. Customs. The key item in this packet of documents from an accounting perspective is the commercial invoice from the seller to the importer. The duty is then calculated based on the value of the goods, which includes the cost of any insurance and freight.
Next, within ten working days after filing this information with U.S. Customs, the importer submits CBP Form 7501, which is called the Entry Summary, along with the calculated duty. Payments are mostly made to the government by ACH, so it’s a direct debit from the importer’s bank. In limited cases, you can also pay with a credit card or a check.
U.S. Customs then reviews the documents and the payment. If everything checks out, then the goods are released for delivery. Sometimes, Customs may hold the goods for inspection, or request additional information.
And then, there are situations in which the importer wants to request a refund from U.S. Customs, which is known as a drawback. You can get a refund when you either destroy imported goods or turn around and export them back out of the country. An importer can also get a drawback for imported materials that are used to manufacture goods that are later exported. There are some paperwork requirements for this, but basically, an importer has to file a drawback claim within five years of the import date. Otherwise, no luck with the refund. Also, U.S. Customs will retain a one-percent processing fee on the refunded amount, though this only applies to certain types of drawbacks. Getting the refund can take months – figure on waiting anywhere from three to six months for it.
Accounting for Tariffs
So, what is the accounting for all of this? Well, the first accounting issue is making sure that you properly aggregate the cost of the imported goods, so that it includes the cost of freight and insurance. This is the customs value, and it’s the basis for calculating the amount of the duty.
Next, multiply the customs value by the applicable tariff rate to estimate the duty. Based on this estimate, create an accrual entry that debits a duty expense account for the amount of the duty, and credit an accrued liability account. This duty is added to the cost of the imported goods.
Then, when you pay the duty amount to U.S. Customs, debit the accrued liability account for the amount paid, and credit your cash account.
In addition to all that, it’s quite possible that there are some uncertainties about either the customs value that was used to calculate the duty, or the tariff rate that was applied to it. If so, there’s a reconciliation process that you can enter into with U.S. Customs, which might result in an alteration to the duty amount. If so, that calls for another accounting entry, which might occur well after the imported goods have already been sold. If so, this could result in a significant increase or decrease in the importer’s cost of goods sold, and possibly well after the fact.
The Financial Investment Impact of Tariffs
That covers the accounting. But in addition, I’d also like to cover the current tariff situation from the perspective of the chief financial officer. When you’re a CFO, the really large capital investment decisions are always going to go across your desk. For example, building a car assembly plant in Mexico, versus the United States. These types of massive investment decisions are based in part on the existing tariff rates, as well as expectations for where those rates will be during the discount period for the investment – which probably covers something in the range of ten to twenty years.
As long as you have some certainty about the applicable tariff rates, then you can make an investment decision, and reasonably expect a decent outcome.
It’s usually not too hard to do so, since the existing tariffs are covered by a treaty – in my example, that would be the USMCA Agreement, which covers the U.S., Canada, and Mexico. The president can override that treaty, because Congress has given him the authority to adjust tariffs on imports that threaten to impair national security. I’m not entirely sure how the import of cars assembled in Mexico is a threat to national security, but that’s how he has the authority to do this.
So, let’s say that the tariff suddenly goes up by 25%, and then the change is withheld at the last minute, and then it’s imposed again the next month, and so on, and so on. As a CFO, what do you do? One option is to rebuild the assembly plant in the United States, but keep in mind that these are massive investments, and they take years to construct. And you also have to convince suppliers to set up their operations adjacent to your new plant. And then there’s also the issue of higher expenses for pretty much everything in the U.S., as well as construction delays from permitting. If you were to rebuild everything in the U.S., then the cost to construct a car goes up – by a lot – which means that you have to increase the prices of your cars, which in turn will probably drop demand. And that will kill your profits.
So, again, what do you do? If it were me, I’d review every pending project to see which ones have the lowest cost disadvantage in the United States, and which can be built fast, and then use those commitments to try to keep avoiding the imposition of new tariffs on cars coming in from Mexico. Basically, do the minimum until the next administration comes along in four years, and hope for more stability with tariffs.
In short, constantly threatening big tariff increases will probably result in a small increase in U.S. investments in the short-term, but overall, I can see the major corporations looking at their investment calculations, and deciding that the prudent thing to do is to just wait for four years. Which, overall, results in less investment.