Client Alerts

FMC Reviews Carrier Billing Practices

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 […]

Treasury Expands Sanctions on Iranian Financial Institutions; Census Confirms BIS Rules for EEI Filing Requirements Under New MEU Rule

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, […]

NBAA & NATA Submit Comments Addressing NPRM on FET Exemption for Business Aircraft Management Services

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 […]

The Named Account Rate Conundrum

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 […]

IRS Issues New Proposed Regulations for Aircraft Management Companies

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 […]

Executive Order 13936 on Hong Kong Normalization

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 […]

FAA REGULATORY ALERT: NBAA Small Aircraft Exemption Extended and Modified

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 […]

BIS Suspends EAR License Exceptions for Hong Kong

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). […]

Navigating New Antitrust Snares While Driving Post-COVID Economic Health and Revenue

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 […]

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