IRS PLR: Deductive Value Method for Customs Valuation Does Not Limit Inventory Cost Under Related Party Import Rules (I.R.C. §1059A)

Jan. 6, 2026, 5:21 PM UTC

The IRS has published a private letter ruling on I.R.C. §1059A clarifying that customs value derived using the deductive value method does not limit inventory cost or basis of related party imports. Section 1059A applies only to specific costs considered in both customs valuation and tax basis calculations, not to the final customs value itself when calculated through deductive valuation. [PLR 202552012]

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