Memorandum D17-1-21, Maintenance of Records in Canada by Importers –Update
September 16, 2022
On August 18, 2022 we advised members of the new BSF900 form and of the updated D 17-1-21, Maintenance of Records in Canada by Importers on August 26, 2022. Further information has been obtained from the CBSA that members may find helpful.
- BSF900 is a requirement for all importers who maintain records at a location other than their place of business or keep them outside of Canada (USA or Mexico). This would also include Canadian importers who are maintaining their records at a location other than their place of business in Canada - either in the USA, Mexico or elsewhere in Canada.
CSCB note, in R2 of CARM any new portal registration of a non-resident importer or of a resident importer keeping their books and records at a place other than their place of business will require the BSF900 to be completed at the time of registration!
- The following is a list of items that may be requested during a verification (list is not exhaustive):
- Canada Customs Coding Forms (B3);
- B3 Recap Sheet (if applicable);
- Purchase Order;
- Commercial Invoice;
- Import Permits (if applicable);
- Proof of payment;
- Bill of lading;
- Freight invoice (if applicable);
- Screen prints of the importer’s accounting entries for purchasing and payments;
- Financial statements (audited if available);
- Detailed adjusted trial balance;
- List of foreign goods suppliers;
- Organization chart, identifying the company structure including ownership, affiliates and divisions;
- Reconciliation of the cost of goods sold (COGS) reported on the financial statements to the adjusted trial balance; identifying imported and non-imported goods;
- Corporate T2 tax return including Schedule 125 - Income Statement, Schedule 9 Related and Associated Companies, and T106 Schedule of Related Party Transactions (when applicable); and
- Narrative and/or flowchart documenting the flow of information for the entries.
The third party does not need to have the physical documents on site, but these should be made available, within a reasonable timeframe, upon request.
Our thanks to the member who shared these additional details!