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;