Client Alerts
Client Alert
The U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC) has recently provided guidance or taken action on a number of issues relevant to the forwarding industry. Secondary Sanctions on Iranian Financial Institutions On October 8, 2020, the U.S. Department of the Treasury designated eighteen Iranian banks under Executive Order (E.O.) 13902 (2020), […]
Client Alert
On October 16, 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) implemented a new streamlined procedure for exporters to request six-month extensions of BIS licenses that expire on or before December 31, 2020. These requests for license extensions can be emailed to: LicenseExtensionRequest@bis.doc.gov. BIS estimates that processing will take only two to three […]
Client Alert
Beginning in September 2020, thousands of companies have challenged the Section 301 China Tariffs under List 3 and 4A in the U.S. Court of International Trade. As part of this challenge, companies are seeking a refund of duties paid under List 3 and 4A, as well as revocation of those tariffs. The lawsuits allege that […]
Client Alert
During the course of the Federal Maritime Commission’s (FMC) investigation of the demurrage and detention practices of the vessel operators in Docket No. 19-05, Interpretive Rule on Demurrage and Detention Under the Shipping Act, several parties raised concerns about why they should have been invoiced for any of those or other charges in the first […]
Client Alert
Secondary Sanctions on Iranian Financial Institutions On October 8, 2020, the U.S. Department of the Treasury designated 18 Iranian banks under Executive Order (E.O.) 13902 (2020), which effectively extends secondary sanctions to Iran’s entire financial sector. As a result, foreign financial institutions and companies may be subject to secondary sanctions, Specially Designated National (SDN) designations, […]
Client Alert
The National Business Aviation Association (NBAA) and National Air Transportation Association (NATA) joined forces to draft and submit to the IRS and Department of the Treasury detailed comments in response to the July 31, 2020 proposed Excise Taxes; Transportation of Persons by Air; Transportation of Property by Air; Aircraft Management Services regulations. This notice of […]
Client Alert
Acting on behalf of the National Customs Brokers and Forwarders Association of America, Inc. (NCBFAA), we recently sent a White Paper to the Federal Maritime Commission (FMC) addressing the commercial and regulatory issues arising out of the vessel operators’ (VOCCs) handling of cargo moving under existing, valid service contracts. The thrust of the paper was our […]
Client Alert
The IRS has issued Excise Taxes; Transportation of Persons by Air; Transportation of Property by Air; Aircraft Management Services, proposed regulations relating to federal excise taxes for aircraft owners that utilize aircraft management companies. These proposed regulations, if finalized, would expand on the Tax Cuts & Jobs Act (TCJA) provision that codified that certain amounts […]
Client Alert
On July 14, 2020, President Trump issued Executive Order (E.O.) 13936, setting forth a tranche of regulatory changes enacting the new U.S. policy to treat Hong Kong as part of the People’s Republic of China (PRC). Historically, the U.S. has granted Hong Kong preferential treatment with regard to export restrictions in recognition of Hong Kong’s […]
Client Alert
The FAA recently extended to March 31, 2022 the long-standing exemption that allows NBAA member companies that operate certain small airplanes and helicopters to conduct certain flight operations under Part Section 91.501(b) that otherwise may only be performed under Part 91 by operators of larger, more complex aircraft, including some operations for which compensation is […]