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Who We Are 2017-03-06T10:38:51+00:00

We Take The Term “Drawback Specialist” Seriously.

This is evidenced by our focus on ensuring the majority of our staff members are licensed Customs brokers, are kept appraised on the latest industry news, and contribute to political and regulatory changes. Our company was instrumental in the formation of the current duty drawback regulations for the U.S. and continues to play an active role in the following ongoing revisions.

We have been actively involved with the negotiations for the recently passed Drawback Simplification bill that is part of the Trade Facilitation and Trade Enforcement Act of 2015 and have a representative on the regulations writing committee.

Most of the wording changes in the drawback portion of the Customs Modernization Act were either written by us exclusively or in collaboration with U.S. Customs and Border Protection and a few other participants. The drawback portion of the Customs Modernization Act was subsequently brought before the U.S. House of Representatives through our direct initiative.

We introduced the concept of “unused merchandise” to replace that of “same condition merchandise” in 1992. The new concept was subsequently added to the Customs Modernization Act.

We were the only duty drawback specialists to appear in person before the Trade Subcommittee of the U.S. House of Representatives Ways and Means Committee. Comstock and Holt’s President, David N. Simcox, testified before this group to encourage their support for the duty drawback provisions of the Customs Modernization Act.

Holt submitted written testimony to the Senate Committee on Finance concerning the Customs Modernization portion of the Trade Expansion Act.

Much of the language in the duty drawback section of the Customs Modernization Act was written by a Comstock colleague who served on a committee charged with the task of drafting this bill.

Representatives from Comstock met with former Customs Commissioner George Weise when he was staff director of the House Ways and Means Subcommittee on Trade. They negotiated details of the drawback portion of the Customs Modernization legislation.

We introduced drawback legislation in the Miscellaneous Trade Act of 2004 and are currently playing an integral role in the introduction of several new bills concerning drawback.

We work with the U.S. Trade Representative’s office for inclusion of drawback rights in Free Trade Agreements (FTA) and in dialogue for potential changes in existing FTAs.

“Our firm has successfully leveraged the services of Comstock & Theakston over several decades. Our continuance reflects our recognition of results. We have always stressed together the key underlying components of compliance in sustaining a viable Duty Drawback program for the long run. We have leveraged Comstock’s education and training opportunities, both in our facilities and at their site, to assure Duty Drawback program knowledge and compliance expectations from both the CBP and company prospective are conveyed and applied. We look forward to continuing this highly valued partnership.”

—Multinational chemical manufacturer

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