James K. Perry

He | Him | His

Associate

Houston
T +1.713.646.1381
F +1.713.751.1717

Overview

James Perry has a well-rounded and broad international trade practice assisting domestic and international clients with trade related concerns before various U.S. Government agencies, including the U.S. Department of Commerce, U.S. Customs and Border Protection, Bureau of Industry and Security and other partner government agencies.

James advises clients in a multitude of industries on U.S. Customs laws and regulations that directly impact clients' importing activities in the U.S., ranging from HTSUS classification, country-of-origin determinations and marking requirements, customs audits, EAPA investigations, international trade agreements (USMCA/KORUS) and other trade remedy matters involving Section 201, 301 and 232 tariffs. He also counsels clients on a variety of export related matters, including the Export Administration Regulations (EAR), U.S. economic sanctions and embargo programs and development of export compliance programs for oil and gas machinery manufacturers and related energy service companies.

In his overall practice, James merges his professional experience working with international companies with his legal experience to provide insightful guidance and analysis to his clients handling complex business decisions driven by constant changes in the regulatory framework governing their business activities.  

Select Experience

  • Successfully passed a Focus Assessment (FA) audit conducted by U.S. Customs for a domestic solar manufacturing company.
  • Drafted submissions of voluntary Prior Disclosures to U.S. Customs and Border Protection, mitigating potential liability exposure for incorrect country of origin declarations, classification and valuation.
  • Submitted Section 232 Steel Exclusions on behalf of oil and gas equipment manufacturers, steel manufacturers and steel distributors.
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Experience

  • Successfully passed a Focus Assessment (FA) audit conducted by U.S. Customs for a domestic solar manufacturing company.
  • Drafted submissions of voluntary Prior Disclosures to U.S. Customs and Border Protection, mitigating potential liability exposure for incorrect country of origin declarations, classification and valuation.
  • Submitted Section 232 Steel Exclusions on behalf of oil and gas equipment manufacturers, steel manufacturers and steel distributors.
  • Representing companies in U.S. Customs and Border Protection enforcement actions.
  • Regularly advising clients on duty exposure for articles subject to Section 201, Section 301 or Section 232 tariffs.
  • Evaluated preferential treatment under various international trade agreements, including United States-Mexico-Canada Agreement (USMCA) and United States-Korea Free Trade Agreement (KORUS).
  • Advising companies on country-of-origin declarations to U.S. Customs and Border Protection in connection to parts and unfinished merchandise assembled or manufactured in various different countries.
  • Preparing detailed and comprehensive submissions for clients issued a CF-28 Request for Information from U.S. Customs and Border Protection.
  • Counsels companies on antidumping and countervailing duty scope orders for imported merchandise.
  • Drafted voluntary self-disclosures (VSDs) to the Bureau of Industry and Security and Office of Foreign Assets Control (OFAC) for potential violations of Export Administration Regulations and U.S. trade and economic sanctions.
  • Submitting voluntary prior disclosures to U.S. Customs and Border on behalf of U.S. companies in connection to post-entry audits and evaluations conducted on country-of-origin declarations, Harmonized Tariff Schedule of the U.S. (HTSUS) classification and valuation of imported merchandise.
  • Advising companies on export control jurisdictional and classification analyses for oil and gas equipment manufacturers exporting assorted items used in the oil and gas industry in various foreign jurisdictions.
  • Assisting clients with the development of import compliance manuals designed to ensure effective controls to comply with U.S. import laws and regulations.
  • Regularly counseling companies on the Harmonized Tariff Schedule of the U.S. (HTSUS) classifications for steel products, oil and gas equipment and numerous of other manufactured commodities.
  • Representing companies involved in Enforce and Protect Act (EAPA) investigations conducted by U.S. Customs and Border Protection.
  • Filed administrative protest on behalf of U.S. companies seeking retroactive application of Section 301 exclusions for refund of duties.
  • Filed Mitigation Petition of Wood Packaging Material penalties incurred by U.S. companies to U.S. Customs and Border Protection.
  • Filed Mitigation Petitions for U.S. companies facing liquidated damages or notice of penalty in relation to imported merchandise entered into the U.S. before various agencies.
  • Counseling companies on Post-Summary Corrections (PSC) to correct entry related information transmitted to U.S. Customs and Border Protection.

Recognitions and Memberships

Memberships

  • State Bar of Texas, International Law Section

Prior Positions

  • American Arbitration Association: AAA Yearbook on Arbitration and the Law Student Scholar (2017 to 2018)
  • The Honorable Marcia A. Crone, U.S. District Court for the Eastern District of Texas: Judicial Intern (2017)

Admissions

  • Texas

Education

  • J.D., University of Houston Law Center, 2019; Houston Journal of International Law, Articles Editor
  • B.B.A., Economics and Management, Sam Houston State University, 2016, summa cum laude