Commercial Payments and Accounts
Accounts Receivable Ledger (ARL) - Fact Sheet on Importer Account Off-Setting
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CBSA has made changes to the way transactions are offset on a client account by changing the prioritization in the offsetting rules.
1. What are the offsetting rule changes?
ARL current month credits will only offset transactions within the billing cycle of the most recent Statement of Account. In other words, ARL will no longer automatically offset transactions belonging to a period prior to the most recent SOA. ARL has updated offsetting rules moving to a newest debt first priority (Last-In / First-Out) for all transaction types. Prior to this release, the priority was assigned to the oldest debt first (First-In / First-Out) for all transaction types.
2. How will credits on my account be applied to outstanding debits with the new offsetting rules?
Current credits will be used to offset current debits in the following order:
| Type of Credits | Type of Debits |
|---|---|
| 1. Payments | 1. B3 (including LAP) |
| 2. B3 (Cancellations of LAP) | 2. B2 |
| 3. B2 Refunds, K32 Drawbacks, K9 Cancellations, NPA Cancellations | 3. NSF |
| 4. NPA, K9 | |
| 5. K23 | |
| 6. Interest |
Please note, each credit types 1 through 3 will be used to offset all of the debit types before moving on to the next credit type on the list; i.e. payments will clear debit types 1 through 6. If there are any remaining debits, B3 (Cancellations of LAP) will offset debit types 1 through 6. If there are still remaining debits, then B2 refunds, K32 drawbacks, K9 cancellations, and NPA cancellations will be used to offset them. Any remaining credits will remain on the account and will be factored in the next SOA.
3. What is the process if I want to pay a specific debit?
There is no change to the current process. Please continue to provide your payment with instructions to CBSA staff specifying which debits to offset with the payment.
4. What is a typical monthly ARL cycle?
Transactions appearing on Daily Notices issued on the 25th to the 24th of any given month will be included on the monthly Statement of Accounts (SOA) issued on the 25th.
5. Will a DAS still be mailed to the client and the broker?
Yes, by default the DAS will be mailed to the importer of Record at the business address for the RM account. If box 10 is completed, a copy of the DAS will be mailed to the "agent" identified in that field.
6. If a B2, submitted by an agent, results in an amount owing, can it still be paid at a CBSA cash office?
Yes, the DAS can be paid in person at a CBSA office on or before the due date. As is current practice, the importer of record will be responsible for payment of the DAS. A list of payment offices can be found on the CBSA website.
7. If broker A confirms release of an entry and broker B files a refund B2 using their own account security, which broker will see the credit on their Daily Notice (DN)/Statement of Account (SOA)?
Broker B will see the credit on their DN/SOA.
8. If the due date of a B2 occurs before the due date of the SOA, will the importer need to make a payment before the SOA to avoid late penalties?
Yes, the importer will need to make a payment to avoid late penalties as due dates for B2s do not necessarily conform to SOA due dates. The due dates for B2s are shown with each B2 transaction when posted on the DN. The CBSA is looking at consolidating B2 and SOA due dates in the near future to avoid this confusion.
9. For B2s resulting in an amount owing to the CBSA, that is approved during the middle of a payment cycle, will the amount be included in the amount owing on the SOA of the same month, even if the payment due would actually be 30 days after the decision date?
Yes, the amount will be on the statement as it is considered a "pending debt" however the due date will also be displayed. If the payment is made after the specified due date for that transaction, it is considered late and interest will be charged accordingly.
10. Where will B2 and drawbacks show up on the importer statement (DN/SOA); the importer or broker portion?
That depends on who files them. If a broker filed the B2 and drawback, then they will also appear on the broker's statement.
11. Will drawbacks have the same "Disbursed" and "Off-set" statuses that B2s will have on the broker and importer SOA?
Yes, these will function in a similar manner to the B2s. If box #2 on the K32 form is completed, as indicated above, the drawback will be associated with, and appear on, that "agent's" (broker/consultant) SOA.
12. If the importer of record is a non-resident importer in the USA, will cheques be sent directly to the non-resident importer in the USA?
Yes.
13. To what address will the CBSA issue disbursement cheques?
All cheques will be made payable to the legal entity and sent to the mailing address for the legal entity that the Canada Revenue Agency has on file related to the business number (BN9) for the importer of record.
14. Will disbursement cheques include a transaction summary for reconciliation purposes?
Public Services and Procurement (PSPC) has stopped including transaction summaries with cheques issued. Transactions summaries can be provided for reconciliation purposes by contacting the CARM mailbox.
15. When will interest be calculated on credit B2's?
Section 80 of the Customs Act indicates that interest is payable as of the 91st day from the submission of the B2 and ends on the day the refund is granted. It is the issuance of the DAS that constitutes the granting of the refund. Once the DAS is issued, the credit should appear on the DN within 24 hours. Any refund approved after 90 days is subject to interest and this would be included in the amount of the credit applied to the importer account.
16. How will a credit posted between the 25th of a given month and the last business day appear in ARL?
It will offset the next billing cycle's debt if a credit is posted between the 25 of one month and the 1st of the next month.
17. When we present a cheque for payment on a B2, will this payment show on a DN?
Yes, this will appear on the following day's DN.
18. If there is an importer credit which is greater than their monthly transactions (for an importer who uses the broker's ASEC) will the balance offset the broker total owing for that importer?
Yes, if the credit is associated with a refund or drawback request filed by that broker.
19. Are partially used credits broken out into two lines under the "Other Transaction" section?
Yes. For the partially used credits you should see two transactions: 1) Residual available credit for offset and 2) Amount used to offset.
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