Client Alerts
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 […]
Client Alert
Effective Tuesday, June 30, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) suspended all License Exceptions in the Export Administration Regulations (EAR) for exports and re-exports to Hong Kong, and in-country transfers within Hong Kong, that are not available for exports, re-exports, or in-country transfers to the People’s Republic of China (PRC). […]
Client Alert
Between June 29 and Sept. 27, 2020, the new EEI filing requirements for exports to China, Russia, and Venezuela will only apply to ECCNs listed in Supp. No. 2 to Part 744 This past April, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) issued new rules to modify the Export Administration […]
Client Alert
For most trade associations and professional societies, the coronavirus pandemic has resulted in major reductions in member’s revenues. With retail stores closed and professional practices dependent on virtual meetings between professionals and clients/patients, non-essential industries and professions experienced devastating decreases in revenue. Now that the economy is reopening, members of trade associations and professional societies are asking […]