About the Firm

Biographical Information


U.S. Foreign-Trade Zone Experience

U.S. Foreign-Trade Zone Services

Articles and Information About Foreign-Trade Zones

Briefings Newsletter

What's New

2013 Seminars

Importer Data Analysis

Exporter Data Analysis

Export Compliance

Export Compliance Plan

Customs-Trade Partnership Against Terrorism (C-TPAT)/Action Plan

Federal Register Notice Documents on Public Inspection

Focused/ Compliance Assessment Plan

Foreign-Trade Zones








Miller & Company is a law firm serving a diverse clientele in import, export, and foreign-trade zone law.  Within these specialized areas of practice, we have received global recognition for our involvement in the development of the U.S. Foreign-Trade Zones Program.  The firm has a broad client base in fifty states, Puerto Rico, and in major trading centers throughout the world.  Clients range from large multinational enterprises to corporations, partnerships, associations, governmental entities, and individuals.  Most business clients involved in international trade rely on us for a comprehensive range of innovative trade-related representation.


The firm’s professionals promptly deliver practical, effective, and quality legal services.  While many activities are on an issue-specific basis, special emphasis is placed on careful strategic business and legal planning prior to the establishment of new or reorganized activities.  The firm does not have a general practice or full-service mentality, allowing each attorney and legal assistant to develop specialized expertise consistent with the firm’s practice.  We have extensive experience with the structuring of import and export activities, governmental compliance and audits, establishment of U.S. and foreign operations, organization, establishment, management, and reorganization of U.S. foreign-trade zones and subzones, development of necessary export compliance strategies, company licensing and representation relationships, and assisting clients with transnational commercial matters.


From its founding in Kansas City and the subsequent establishment of its Washington, D.C. and New York offices, the scope of services has grown steadily in the international arena.  In U.S. Customs, export, foreign-trade zones, and international trade matters, the firm has practiced extensively before local, port, area, regional, and Washington, D.C. government offices throughout the United States and Puerto Rico.  We have substantial experience in dealing with U.S. Customs and Border Protection (hereinafter referred to as “Customs”); U.S. Foreign-Trade Zones Board; U.S. Department of Commerce - International Trade Administration, Office of Textiles & Apparel, Bureau of Industry and Security, Bureau of the Census; U.S. International Trade Commission; Office of the U.S. Trade Representative; Food & Drug Administration; U.S. Department of Agriculture; Federal Trade Commission; Internal Revenue Service; Environmental Protection Agency; Department of Energy; Drug Enforcement Administration; U.S. Treasury Department-Office of Foreign Assets Control, Bureau of Alcohol, Tobacco & Firearms; General Accounting Office; the Department of Defense; and the U.S. Department of State.  We regularly engage in liaison activities on behalf of our clients with the U.S. Senate, U.S. House of Representatives, the Executive Branch, the White House, and foreign governments.


In the import, export and foreign-trade zone law areas, the firm has assisted its clients in matters concerning:

·     Import/export classification and valuation of merchandise;

·     Country of origin marking and merchandise labeling requirements;

·     Customs dutiability of royalties, license fees, buying and selling commissions, assists, and proceeds of subsequent resale on imports/export;

·     Effect of rebates, resale proceeds, and consignments on imports and exports;

·     Establishing and administering Reconciliation Prototype programs;

·     Securing binding Customs Headquarters and Commerce Department Rulings;

·     HTSUS/ECCN Classifications;

·     Fines, penalties, seizures, and forfeitures related to international trade;

·     Mitigating Customs penalty and liquidated damage assessments;

·     Representing firms subject to Customs Focused Assessments/audits/Census audits;

·     Compiling and analyzing Customs import and Census export activity data with extensive proprietary software;

·     Preparing import/export compliance programs/operations manuals;

·     Export Voluntary Self Disclosures/Import Prior Disclosures;

·     Preparing Foreign-Trade Zone Applications, FTZ Inventory System Designs, Operations Manuals, securing Activation of foreign-trade zones, subzones, and supporting ongoing operations, and schedules;

·     Establishing and operating bonded warehouses, and duty free shops;

·     Establishing and maintaining a drawback program;

·     American Goods Returned transactions (Headings 9801 and 9802, HTSUS);

·     Temporary Importation Bond (TIB) compliance;

·     Use of the Prototype Provision;

·     Antidumping/Countervailing duty, and unfair trade practices questions;

·     Customs protection of patents, trademarks, and trade names;

·     Quota, voluntary restraints, and orderly marketing arrangements;

·     Structuring participation/re-evaluations in the Customs-Trade Partnership Against Terrorism (C-TPAT);

·     Census reporting for imports and exports;

·     Evaluation of automated export software vendors for Restricted Party Screening (RPS) and export license determination;

·     AES/EIN Automated Export System compliance;

·     Applications for Commerce and State Department export licenses (EAR/ITAR/OFAC);

·     Export licensing and enforcement compliance;

·     Encryption Process;

·     Deemed Export Assistance and Processes;

·     Technology Control Plans;

·     Jurisdiction Determinations;

·     Commodity Jurisdictions;

·     Embargo Country Guidance;

·     International Antiboycott compliance;

·     Foreign Corrupt Practices Act questions;

·     Implementation and practical implications of WTO/WCO Agreements;

·     Unfair trade actions under Sections 201 and 301 of the Trade Act of 1974, as amended; Unfair trade actions under Section 337 of the Tariff Act of 1930, as amended;

·     Proceedings before the World Customs Organization;

·     Qualification and compliance issues under the North American Free Trade Agreement (NAFTA), Singapore, Chile, Australia, Peru, CAFTA, Israel, Jordan, Morocco, Bahrain, Oman, and pending Colombia, Korea, and Panama;

·     Caribbean Basin Initiative and United States-Israel Free Trade Area activities;

·     Generalized System of Preferences petitions and proceedings;

·     Direct investment, joint ventures, licensing, and sales agreements;

·     Letters of credit and international guarantees;

·     Bond compliance and violations;

·     Impact of United States Federal Sentencing Guidelines;

Our practice covers a wide range of constantly changing import, export, and foreign-trade zone trade issues.  This includes assisting clients in qualifying products for preferential treatment, developing strategies for structuring transactions in order to maximize Customs duty savings opportunities, and participating in the process of creating and implementing regulations.  The Customs Modernization Act significantly changed the Customs environment, resulting in increased responsibilities to importers, new recordkeeping requirements and new penalty provisions.  We advise our clients on all changes applicable to their trade activities and assist in developing and maintaining effective Customs compliance efforts.  We provide a comprehensive, non-traditional export compliance program that provides the necessary guidance on the requirements of enhanced export programs.  Customs has also placed new emphasis on tariff classification, valuation of imported merchandise, and country of origin marking.  Clients are guided on how to maximize available duty drawback opportunities while ensuring compliance with all requirements.  The firm is very active in helping clients alleviate burdens, mitigate unexpected additional expenses, and develop proactive strategies for future transactions.  With regard to the North American Free Trade Agreement (NAFTA) and an increasing array of other Free Trade Agreements, we perform such services as evaluating potential duty savings and marking requirements, analyzing which products qualify for FTA benefits, assisting clients in complying with all applicable U.S., Mexican, Canadian, and other national governmental requirements, and representation during Customs information requests and audits.


Regulatory changes to the collection of export information have a significant impact on the trade community. The implementation of full mandatory filing of export data, through the Automated Export System has added specific timeframes for filing export data and severe penalties for failing to comply with the new requirements. The firm provides quality training in understanding the complexities of the Foreign Trade Regulations, the Export Administration Regulations and the International Traffic in Arms Regulations. Additionally, we have programs that analyze Census data and identify potential compliance issues. We can prepare and submit, on behalf of our clients, voluntary self-disclosures.


Miller & Company has unparalleled experience in all aspects of the U.S. Foreign-Trade Zone Program.  Its Principal was a Founder and has served as General Counsel to the National Association of Foreign-Trade Zones since its inception in 1972.  The firm previously managed the Association.  We have been instrumental in formulating U.S. policies and procedures affecting foreign-trade zones.  The firm structured the zone production environment for the motor vehicle, oil refining, shipbuilding, pharmaceutical, and information technology industries among others.  As General Counsel to the National Association of Foreign-Trade Zones, the firm supervised seven investigations and reports on the zones program by the General Accounting Office and the U.S. International Trade Commission and presentation of testimony at two Congressional hearings examining the zones program.  Significant changes to the U.S.-Canada Free Trade Agreement and the North American Free Trade Agreement were negotiated by the firm.  Miller & Company has represented and/or helped structure more than 550 general-purpose foreign-trade zones and special-purpose manufacturing subzones projects.

In 1998, the firm’s Principal was a recipient of Vice-President Al Gore’s Hammer Award for his outstanding contributions to improving the Customs trade compliance process.  The firm has represented numerous Japanese companies that have established major manufacturing and business enterprises in the U.S., and in 2004, the firm’s Principal was one of only two persons worldwide to be presented, “The Order of the Sacred Treasure” decoration by His Majesty Emperor Akihito of Japan for his significant contributions toward deepening friendship and understanding between the people of Japan and the U.S.

Miller & Company provides its clients with information concerning international trade issues on its web site at www.millerco.com Briefings is our monthly newsletter highlighting current key international trade developments for clients.  We conduct seminars on topics of special interest exclusively for our clients at our headquarters in Kansas City, Missouri and on-site at client facilities.  The firm produces and distributes A Reference Guide to U.S. Foreign-Trade Zones, the only publication of its kind that provides both historical and current document providing comprehensive information on all zone projects.      


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