26 USC § 1059A - Limitation on taxpayer’s basis or inventory cost in property imported from related persons

---
identifier: "/us/usc/t26/s1059A"
source: "usc"
legal_status: "official_prima_facie"
title: "26 USC § 1059A - Limitation on taxpayer’s basis or inventory cost in property imported from related persons"
title_number: 26
title_name: "INTERNAL REVENUE CODE"
section_number: "1059A"
section_name: "Limitation on taxpayer’s basis or inventory cost in property imported from related persons"
chapter_number: 1
chapter_name: "NORMAL TAXES AND SURTAXES"
subchapter_number: "O"
subchapter_name: "Gain or Loss on Disposition of Property"
part_number: "IV"
part_name: "SPECIAL RULES"
positive_law: false
currency: "119-84"
last_updated: "2026-04-17"
format_version: "1.1.0"
generator: "[email protected]"
source_credit: "(Added Pub. L. 99–514, title XII, § 1248(a), Oct. 22, 1986, 100 Stat. 2584.)"
---


# § 1059A. Limitation on taxpayer’s basis or inventory cost in property imported from related persons

**(a)** **In general** If any property is imported into the United States in a transaction (directly or indirectly) between related persons (within the meaning of section 482), the amount of any costs—

shall not, for purposes of computing such basis or inventory cost for purposes of this chapter, be greater than the amount of such costs taken into account in computing such customs value.

**(1)** which are taken into account in computing the basis or inventory cost of such property by the purchaser, and

**(2)** which are also taken into account in computing the customs value of such property,

**(b)** **Customs value; import** For purposes of this section—

**(1)** **Customs value** The term “customs value” means the value taken into account for purposes of determining the amount of any customs duties or any other duties which may be imposed on the importation of any property.

**(2)** **Import** Except as provided in regulations, the term “import” means the entering, or withdrawal from warehouse, for consumption.

---

**Source Credit**: (Added Pub. L. 99–514, title XII, § 1248(a), Oct. 22, 1986, 100 Stat. 2584.)

## Statutory Notes and Related Subsidiaries

### Effective Date

> “The amendments made by this section [enacting this section] shall apply to transactions entered into after
> 
> .”

, , , provided that: