---
kind: "section"
citation: "26 U.S.C. § 1059A"
title: "26"
title_heading: "Internal Revenue Code"
number: "1059A"
heading: "Limitation on taxpayer’s basis or inventory cost in property imported from related persons"
release: "119-102"
date: "2026-07-12"
url: "https://uscodex.org/usc/26/1059A"
units:
  - "Subtitle A — Income Taxes"
  - "Chapter 1 — Normal Taxes and Surtaxes"
  - "Subchapter O — Gain or Loss on Disposition of Property"
  - "Part IV — Special Rules"
---

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

- (a) **In general—** If any [property](/usc/26/317.md?p=a) is imported into the [United States](/usc/26/993.md?p=g) in a transaction (directly or [indirectly](/usc/26/101.md?p=a-3-B)) between [related persons](/usc/26/414.md?p=n-6-A) (within the meaning of [section 482](/usc/26/482.md)), the amount of any costs—
  - (1) which are taken into account in computing the basis or inventory cost of such [property](/usc/26/317.md?p=a) by the purchaser, and
  - (2) which are also taken into account in computing the customs [value](/usc/26/851.md?p=c-4) of such [property](/usc/26/317.md?p=a),

  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](/usc/26/851.md?p=c-4).

- (b) **Customs value; import—** For purposes of this section—
  - (1) **Customs value—** The term “customs [value](/usc/26/851.md?p=c-4)” means the [value](/usc/26/851.md?p=c-4) 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](/usc/26/317.md?p=a).
  - (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.)

## Notes

### Statutory Notes and Related Subsidiaries

### Effective Date

Pub. L. 99–514, title XII, § 1248(c), Oct. 22, 1986, 100 Stat. 2584, provided that: “The amendments made by this section [enacting this section] shall apply to transactions entered into after March 18, 1986.”