US Aluminum/Steel Tariffs and Irish/NI Companies

Several Irish and NI companies have asked me whether the recently-imposed US tariffs on aluminum and steel would impact their products–products that use/incorporate aluminum and steel. Much of the confusion stems from how the tariffs were developed and publicized. The bottom line is that US steel/aluminum tariffs should not impact most Irish or Northern Irish companies.

As for the tariffs, for goods entered, or withdrawn from a warehouse for consumption, on or after March 23, 2018, there will be a (i) 10% ad valorem tariff on defined “aluminum articles” imported from all countries except Canada and Mexico; and (ii) a 25% ad valorem tariff on defined “steel articles” imported from all countries except Canada and Mexico.

Under the tariff proclamation, “aluminum articles” are defined in the Harmonized Tariff Schedule (HTS) as: (i) unwrought aluminum (HTS 7601); (ii) aluminum bars, rods, and profiles (HTS 7604); (iii) aluminum wire (HTS 7605); (iv) aluminum plate, sheet, strip, and foil (flat rolled products) (HTS 7606 and 7607); (v) aluminum tubes and pipes and tube and pipe fitting (HTS 7608 and 7609); and (vi) aluminum castings and forgings (HTS 7616.99.51.60 and 7616.99.51.70). “Steel articles” are defined at the HTS 6 digit level as: 7206.10 through 7216.50 including ingots, bars, rods and angles), 7216.99 through 7301.10 (including bars, rods, wire, ingots, and sheet piling), 7302.10 (rails), 7302.40 through 7302.90 (including plates and sleepers), and 7304.10 through 7306.90 (including tubes, pipes and hollow profiles).

The tariffs cover unfinished products that would be used an inputs for finished products, and not for products that incorporate or use aluminum or steel. There is a very low volume of imports from Ireland ant the UK under the covered tariff headings. As stated above, the bottom line is that US steel/aluminum tariffs should not impact most Irish or Northern Irish companies.

 

How to Open a U.S. Bank Account

Just back from a two-week swing through Belfast, Antrim (at a wonderful InvestNI program) Londonderry/Derry, Galway, and Dublin, meeting with companies looking to export to the U.S. One question that came up time and again: how can an Irish or NI company open a U.S. bank account?

Opening U.S. bank accounts has become harder because of the ‘know-your-customer’ requirements on U.S. banks by virtue of U.S. anti-money laundering regulations. In general (and keep in mind that some banks may have other specific requirements), in order to open a U.S. bank account, a bank will want to see (i) a certified copy of your U.S. affiliate’s certificate of incorporation/formation; (ii) your entity’s taxpayer ID number from the IRS; and (iii) a signed copy of your U.S. affiliate’s initial consent in lieu of a board meeting, which consent should include banking authorization language (see the sample consent here). The pain-in-the-neck part is this: you’ll need someone to actually go to the U.S. bank (with his/her passport and another form of ID) to open the account. The banks want to be sure that the account holders are who they say they are. Often, Irish/NI parent companies will open the account when one of their executives travels to the U.S. on other business.

Derry/Londonderry Doing Business in the U.S. Event–September 7

Related to yesterday’s post, I’m also thrilled to be speaking at a Doing Business in the U.S. program in Derry/Londonderry on the morning (8:30) of  September 7, at Invest Northern Ireland’s office there. I’ll also be using the Invest NI office for the balance of the 7th as my ‘office’ in case people need to speak about U.S. expansion. Looking forward to it, and thanks to the great help from @investNI, @investNI_USA, @derry_chamber, and @investdcsdc. Contact Invest NI’s Derry/Londonderry office for more information.