The massive stimulus package approved by Congress late yesterday includes long awaited relief for many 501(c)(6) organizations. The package makes 501(c)(6) organizations eligible for loans under the Paycheck Protection Program (PPP) if they meet the following requirements: The organization does not receive more than 15% of receipts from lobbying; The lobbying activities do not comprise […]
On December 14, 2020, the U.S. Department of State imposed broad sanctions on Turkey’s Presidency of Defense Industries (also known as SSB) pursuant to Sections 231 and 235 of the Countering America’s Adversaries Through Sanctions Act (CAATSA), including a prohibition on U.S. government agencies from providing U.S. export licenses and authorizations for transfers of goods and technology […]
On November 19, 2020, the Federal Maritime Commission (FMC) issued a supplemental order expanding the scope of Fact-Finding Investigation No. 29 (FF No. 29). As you may recall, the FMC opened FF No. 29 earlier this year in response to the disruptive effects COVID-19 has had on trade and for the purpose of identifying solutions for some […]
GKG Law Principal Ed Greenberg and Associate Kristine Little submitted the below comments to the Federal Maritime Commission (FMC) on behalf of the National Customs Brokers and Forwarders Association of America (NCBFAA) in response to the agency’s Notice of Inquiry (NOI) that was looking into the propriety of steamship line billing practices. In a growing number of instances, […]
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), […]
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 […]
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 […]
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 […]
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, […]
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 […]