International

The One Big Beautiful Bill Act (OBBBA) was passed by the U.S. House of Representatives on May 22, 2025 by a narrow vote of 215-214. OBBBA includes a new U.S. tax provision that could significantly increase taxes on foreign companies and investors—especially those from countries like France that have implemented digital services taxes or other similar measures. The new bill introduces a new section to the U.S. Internal Revenue Code Section 899.
Continue Reading U.S. Budget Bill Targets Foreign Companies with New Tax Hikes: What French Businesses Need to Know

In a significant shift in international policy, the United States, European Union, and United Kingdom have each taken steps to ease sanctions on Syria, aiming to support the country’s reconstruction and political transition following the fall of the Assad regime.
Continue Reading Syria-ous Changes for Middle East Business? The United States, UK, and Europe Relax Sanctions on Syria

On May 28, 2025, a three-judge panel of the U.S. Court of International Trade (CIT) unanimously struck down the extensive tariffs imposed by President Trump under the International Emergency Economic Powers Act (IEEPA). The CIT held that the imposition of the tariffs exceeded the authority granted to the President by Congress under IEEPA. The Court issued a permanent injunction blocking the administration from enforcing the IEEPA tariffs, and ordered the administration to issue the necessary administrative orders within 10 days to end them. In response, the government appealed the case to the U.S. Court of Appeals for the Federal Circuit.
Continue Reading Federal Court Strikes Down IEEPA Tariffs

Years ago, when I was a baby lawyer living in a group house in DC, we had a toaster—my toaster. I had owned the toaster since college and it was showing its age. Eventually, you had to hold down the thing[1] to keep the bread lowered in the slots and toasting. But the appliance still heated bread and produced toast. One morning, I became so frustrated with that toaster and the thing-holding-down effort that I threw the toaster out, fully intending to get a new toaster.

The following day, my housemate, we’ll call him Mike,[2] raised an important
Continue Reading Throwing Away the Toaster: Where AI Controls Are Now and May be Heading

The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and directives have come so thick and fast that it is not always simple for businesses to chart a consistent policy direction and develop their plans to account for what might be coming next.
Continue Reading A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part III

The implementation of new 25% Section 232 duties on steel, aluminum, and certain derivatives, effective March 12, 2025, which are in addition to any special rate of duty otherwise applicable, are affecting importers globally. Here is a breakdown of what these new tariffs entail:
Continue Reading Overview of Section 232 Tariffs on Steel and Aluminum: What Importers Need to Know

The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and directives have come so thick and fast that it is not always simple for businesses to chart a consistent policy direction and develop their plans to account for what might be coming next.
Continue Reading A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part II

The second Trump administration has come flying out of the starting blocks on international trade policy actions—imposing and rescinding, shaping and reshaping tariffs, sanctions, and export controls. The executive orders and directives have come so thick and fast that it is not always simple for businesses to chart a consistent policy direction and develop their plans to account for what might be coming next.
Continue Reading A Roadmap for Export Controls? Project 2025 and the Future of U.S. Exports – Part I

On April 16, 2025, the Department of Commerce announced that it initiated an investigation on April 1, 2025, under Section 232 of the Trade Expansion Act, into imports of semiconductors, semiconductor manufacturing equipment (SME), and related products to evaluate how those imports may impact national security.
Continue Reading Who is Stacking the Chips: U.S. Commerce Department Launches Section 232 Investigation into Semiconductor Imports

In the context of the tariffs imposed by the Trump Administration on imported goods, a prevalent misconception has arisen that foreign suppliers automatically bear the cost of these tariffs. The reality, however, is more complex. The actual payment of tariffs is significantly influenced by the specific contractual agreements between U.S. buyers and their foreign suppliers.
Continue Reading Understanding the Allocation of Tariff Payments

On April 2, President Trump issued an Executive Order (EO) imposing global reciprocal tariffs (White House Fact Sheet). The EO drew enough parallels to the Smoot-Hawley Tariff Act that Trump mentioned it in his Rose Garden announcement. The EO imposes a 10% baseline tariff on all imports to the United States beginning April 3, 2025.
Continue Reading Blockading the Ports: U.S. Imposes 10% Global Tariff; Higher Reciprocal Tariff Rates by Country

Last week, the U.S. Embassy in Paris issued a letter and certification form to multiple French companies requiring companies that serve the U.S. Government to certify their compliance with U.S. federal anti-discrimination laws. This certification request was issued in furtherance of President Trump’s Executive Order 14173 on Ending illegal Discrimination and Restoring Merit-Based Opportunities, issued on January 21, 2025. This Order addresses programs promoting Diversity, Equity and Inclusion (DEI) and requires that government contractors’ employment, procurement and contracting practices not consider race, color, sex, sexual preference, religion or national origin in ways that violate the United States’ civil rights laws.
Continue Reading Understanding the U.S. Embassy Paris Certification Requirement

On January 3, 2025, the Cyberspace Administration of China (the “CAC”) released the Draft Measures for Personal Information Protection Certification for Cross-Border Data Transfers (the “Draft Measures”) for public comment. Following the Implementation Rules for Personal Information Protection Certification (the “Implementation Rules”) and the Cybersecurity Standards Practice Guidelines – Security Certification Specifications for Cross-Border Processing of Personal Information V2.0 (TC260-PG-20222A) in 2022, the Draft Measures provides additional details with respect to key aspects of the certification process, including its applicability, evaluation criteria, implementation process, use of certification results, and post-certification supervision. 
Continue Reading Draft Measures for Personal Information Protection Certification for Cross-Border Data Transfers Released for Public Comment

UPDATE: On February 5, 2025, the Trump administration issued an executive order delaying the cancellation of de minimis until “adequate systems are in place to fully and expediently process and collect tariff revenue applicable”. Imports from China below the value of $800 will generally not be subject to the 10% tariff or Section 301 duties.
Continue Reading The First Wave: U.S. Imposes Tariffs on Canada (or not?), Mexico (or not?), and China (well, yeah, probably so)

Tariffs remain the focus of the incoming Trump Administration. Over the past several months, the announcements from president-elect Trump and his transition team have been dynamic. We expect the Trump trade policy team to use creative methods to deliver aggressive new tariff policies this year.
Continue Reading Trump Tariffs Survival Guide: 10 Strategies for U.S. Importers