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Significant Cuts to IRA Clean Energy Tax Credits Included in Enacted Reconciliation Bill

President Trump signed the “One, Big, Beautiful Bill Act” (the “OBBB”) into law on July 4, 2025. Congress passed the legislation using the budget reconciliation process to avoid the 60-vote Senate filibuster. In addition to...more

House Passes Major Cuts to IRA Clean Energy Tax Credit Provisions

On May 22, 2025, the U.S. House of Representatives passed a highly anticipated piece of legislation - commonly referred to as “The One, Big, Beautiful Bill” (the “Bill”) - by a mostly party-line vote of 215-214-1 (two...more

Connected Vehicles Rule to Disrupt Supply Chain and Impose Compliance Obligations

On January 16, 2025, the Bureau of Industry and Security (BIS) published the Final Rule, prohibiting the import of “vehicle connectivity system” (VCS) hardware (including connected vehicles integrating that hardware) and the...more

DHS, Treasury, and CBP Seek to Modify the De Minimis Exemption from Duties and Fees for Low Value Shipments, Including to Prohibit...

19 U.S.C. § 1321(a)(2) authorizes administrative exemptions from duty, tax, and formal entry procedures for shipments of certain imported articles, including articles valued at $800 or less. The importing community often...more

President Trump Orders Tariffs on Canada, Mexico, and China Effective Tuesday, February 4

On February 1, 2025, President Trump signed three executive orders imposing additional tariffs on Canada, Mexico, and China, pursuant to the International Emergency Economic Powers Act (IEEPA) in response to emergencies...more

Unleashing Uncertainty: President Trump’s Federal Funding Freeze

On January 20, 2025, President Donald Trump signed the Unleashing American Energy Executive Order (“Energy EO”) and the Reevaluating and Realigning United States Foreign Aid Executive Order (“Foreign Aid EO”), both portend a...more

Commerce Issues Proposed ICTS Regulations That Would Disrupt Connected Vehicle Supply Chains Involving China and Russia

On September 26, 2024, the Office of Information Communications Technology Services (OICTS) within the Bureau of Industry and Security of the U.S. Department of Commerce published a long-awaited proposed rule to regulate the...more

USTR Concludes its Section 301 “Necessity Review” and Increases Tariffs in Key Sectors

Key Points - Last Tuesday, USTR announced the results of its Section 301 “necessity review.” Today, USTR followed up with a Federal Register notice providing details on the further proposed modifications to the Section 301...more

Commerce Focuses National Security Scrutiny on 'Connected Vehicle' Supply Chain

On March 1, 2024, the Department of Commerce (Commerce), Bureau of Industry and Security (BIS), through its Office of Information and Communication Technology and Services (ICTS), released an advanced notice of proposed...more

Clean Vehicle Tax Credit – Foreign Entity of Concern Rules Proposed

On December 1, 2023, the Department of the Treasury and the Internal Revenue Service (IRS) issued proposed regulations (REG-118492-23) with additional guidance on the excluded entities provision in the section 30D clean...more

Autonomous Systems & Advanced Mobility: 2023 Trends & Predictions

The Autonomous Systems & Advanced Mobility (ASAM) space is headed for more change in 2023, generating new opportunities and challenges for a growing list of industry players. The adoption of new, complex and connected...more

USTR Releases Section 301 China Tariff Necessity Review Comment Form

On November 1, USTR released a comment form prescribing the submission format for public comments in the “necessity review” process for the Section 301 China tariffs. USTR first announced the public comment phase of the...more

Implementation Issues Arise Following Mexico’s Customs Agency Reorganization Under Military Authority

Key Points - On January 1, 2022, Mexico eliminated its General Customs Administration (AGA, by its initials in Spanish), which had operated under the authority of Mexico’s central Tax Administration Service. In its place,...more

International Trade and Customs Alert: New UFLPA Compliance Guidance: An Overview for US Importers and Supply Chain Partners

Key Points - On June 21, 2022, CBP began enforcing the UFLPA’s revisions to section 307 of the Tariff Act of 1930—19 U.SC. § 1307—by applying a rebuttable presumption that the following goods are prohibited from...more

USTR and DOC Seeking Public Comments on Digital Trade Issues under the Indo-Pacific Economic Framework

Key Points - On March 11, 2022, USTR and DOC requested public comments on the trade pillar of the Indo-Pacific Economic Framework, with both requests including a focus on digital trade issues. Comments are due to both...more

The Uyghur Forced Labor Prevention Act: What U.S. Companies with China-Based Supply Chains Should Know

Key Points - On December 23, 2021, President Biden signed the UFLPA into law after it unanimously passed both chambers of Congress. The UFLPA aims to strengthen the forced labor statute by prohibiting the importation and...more

Section 232 National Security Investigation on NdFeB Permanent Magnets Initiated by Commerce

Key Points - The Department of Commerce initiated a Section 232 national security investigation into NdFeB permanent magnets, which are used in fighter aircraft, missile guidance systems, electric vehicles, wind...more

Court of International Trade Issues Preliminary Injunction in Unprecedented Section 301 Litigation

Yesterday, in the unprecedented “In re Section 301 Cases” litigation, the U.S. Court of International Trade (CIT) entered a preliminary injunction that suspends the liquidation of plaintiffs’ unliquidated entries from China...more

As Offshore Wind Energy Projects Expand, So Too Does the Reach of the Jones Act

Key Points - CBP recently ruled that the Jones Act applies to the transportation of merchandise from a U.S. port to locations on the OCS used for developing and producing wind energy, following Congressional amendments to...more

232 Tariffs on Certain Imports of Aluminum from Canada

- In Presidential Proclamation 10060, announced on August 6, 2020, President Trump reinstated a 10 percent ad valorem tariff on imports of non-alloyed unwrought aluminum from Canada under the Section 232 of the Trade...more

FEMA Extends Temporary Final Rule Restricting Certain Exports of PPE

- On August 10, 2020, FEMA extended the duration of its restrictions on the export of certain shipments of PPE through December 31, 2020. - The August 10 notice narrowed the types of PPE covered by the restrictions to...more

The USMCA’s Facility-Specific Rapid Response Labor Mechanism: Are You Ready for It?

- The Facility-Specific Rapid Response Labor Mechanism (RRLM) in the United States-Mexico-Canada Agreement (USMCA) establishes an entirely new streamlined approach to labor dispute settlement in free trade agreements under...more

Brazil Initiates Process to Join the WTO Government Procurement Agreement

- On May 18, 2020, the government of Brazil submitted its application for accession to the WTO GPA, which will further open the Brazilian government procurement market to foreign producers and foreign service providers and...more

Executive Order and CBP Rule Authorize 90-Day Duty Deferral for Certain Imports

- On April 18, 2020, President Trump issued an Executive Order authorizing temporary deferral of certain duty payments, which CBP implemented via a Temporary Final Rule on April 20, 2020 - Importers of record who have...more

FEMA Issues New Exemptions to Temporary Rule Authorizing CBP to Detain Certain Exports of Health and Medical Materials

- Effective April 17, 2020, FEMA expanded exemptions to its April 7, 2020, Temporary Rule that implemented export restrictions on certain shipments of personal protective equipment. - FEMA issued the Temporary Rule to...more

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