Who this applies to
Import/export businesses and wholesale distributors buying goods for resale across state and national lines.
Key questions
- Are customs duties and tariffs being capitalized into cost of goods sold correctly, rather than expensed as ordinary freight?
- Does your inventory costing method still fit now that purchase volume and supplier count have grown?
- Do you know which states require sales tax nexus registration for your resale and drop-ship activity?
Review with the OICPA team
- Confirm customs duties and tariffs are capitalized into COGS, not expensed as a routine freight cost
- Reassess inventory costing method as purchase volume and supplier complexity increase
- Run a multi-state nexus review covering both resale and any direct retail activity
A business built around buying and reselling goods across borders or across states carries a layer of tax complexity that a purely domestic retailer or service business doesn't face: customs duties, currency exposure on foreign supplier payments, and sales tax obligations that follow the business into states where it may have never set foot.
Customs duties and tariffs belong in cost of goods sold, not in a general freight or shipping expense line, and the distinction matters for both accuracy and audit posture. Duties paid to bring imported inventory into the country are a direct cost of acquiring that inventory, the same way the purchase price itself is, capitalizing them into COGS rather than expensing them as an operating cost keeps gross margin reporting accurate and matches how a customs broker or freight forwarder's invoice should actually be coded.
Inventory accounting method choice becomes more consequential as purchase volume and supplier count grow. A business sourcing from a handful of suppliers can often manage inventory costing with a relatively simple approach, but as the supplier base, currency exposure, and product complexity expand, the costing method needs to keep pace, a method that worked cleanly at a smaller scale can start producing distorted COGS and margin numbers once the business outgrows it without anyone revisiting the choice.
Foreign supplier payment currency considerations add a layer most domestic-only businesses never deal with. Paying suppliers in a foreign currency means the actual cost of inventory in dollar terms fluctuates with exchange rates between the time an order is placed and when it's actually paid for, a business that doesn't track this can find its realized cost of goods sold drifting meaningfully from what was originally budgeted, purely from currency movement rather than any pricing change from the supplier.
Multi-state sales tax nexus is the exposure that catches growing wholesale and distribution businesses off guard, often because the mental model is "we sell to other businesses, not consumers, so sales tax doesn't apply to us." Resale certificates handle the exemption on true resale transactions, but a distributor still needs nexus and registration analysis for any direct retail sales, drop-shipping arrangements, or situations where a resale certificate isn't properly collected and kept on file, an uncollected or invalid resale certificate can turn what should have been an exempt sale into an unexpected sales tax liability for the seller.
Drop-shipping arrangements in particular deserve their own look, since they can create nexus questions in states where the business has no employees, no inventory, and no traditional physical presence at all, purely through the mechanics of who's shipping what to whom and on whose behalf.
Landed cost tracking, the fully loaded cost of inventory including purchase price, duties, freight, and any handling fees, is worth building into the accounting system directly rather than reconstructing at year-end, both for accurate margin reporting throughout the year and for a defensible COGS number if the business is ever reviewed.
OICPA works with import/export and wholesale distribution businesses on customs duty and COGS treatment, inventory costing method reviews as purchase complexity grows, and multi-state nexus analysis covering both resale and any direct sales activity.
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