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The relevant amendment changes the existing law "by striking 'on which notice of the original liquidation is given or transmitted to the importer, his consignee or agent' and inserting 'of the original liquidation'.” This should make the relevant date the date on which the deemed liquidation occurs, not the date of notice, which is how it should be (if you ask me).] The second recent case from the Court of International Trade involves the deemed liquidation of an entry. For purposes of my own time management, I am just going to give you the take-aways. The first question is whether Customs and Border Protection can reliquidate a deemed liquidation within the 90-day period set in .


The second question was when the 90-day clock starts to run for the voluntary reliquidation.

The GSP qualification for gold jewelry from Thailand expired with the expiration of the program as a whole.

It was later restored to the list of qualified goods, but it was not on the list of qualified goods on July 1, 1998.

The statutory language for the retroactivity of GSP in 1998 applied to goods qualified for GSP on July 1, 1998.

Despite the fact that gold jewelry from Thailand was NOT qualified for GSP on July 1, 1998, U. Customs refunded the duties Samuel Aaron paid on entry, and then had second thoughts.