Century Importers, Inc. v. United States
United States Court of Appeals for the Federal Circuit
205 F.3d 1308 (2000)
Century Importers, Inc. (plaintiff) agreed to import Molson beer into the United States, and Molson agreed to reimburse Century for new duties imposed during a trade dispute. When the beer arrived, U.S. Customs (defendant) charged duties based on the beer's full invoice price, since the invoice did not mention the later reimbursement; Molson then separately paid Century back for the duties. Century sued for a partial refund, arguing the true price of the beer was really the invoice price minus the promised duty reimbursement. Customs argued that a price reduction not identified on the invoice is just a rebate that doesn't lower the dutiable value. The Court of International Trade sided with Century, and Customs appealed.
Whether, for purposes of calculating import duties, an invoice must identify a price deduction as covering duties in order for that deduction to reduce the dutiable value of the goods.