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Citing Loper, Fifth Circuit Declines Agency Deference, Overturns Sanctions Against Cryptocurrency Software

On November 26, 2024, the Fifth Circuit issued an opinion in Van Loon v. Department of the Treasury that invalidated economic sanctions imposed by the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) on...more

Highly Anticipated Domestic Content Bonus Guidance Released

On May 12, 2023, the Department of the Treasury (the “Treasury”) and Internal Revenue Service (the “IRS”) issued Notice 2023-38 (the “Notice”), providing guidance on the rules taxpayers must satisfy to qualify for the...more

CFIUS Adds New Zealand to Excepted Foreign States List and Finalizes Additional Time for Allies to Secure Excepted Foreign State...

The Committee on Foreign Investment in the United States (“CFIUS”) earlier this month released a fact sheet announcing updates on excepted foreign states determinations, including the addition of New Zealand to CFIUS’s...more

Berkshire Hathaway’s $4.1 Million OFAC Settlement Underscores Risks Of Subsidiaries’ Compliance Failures And Benefits Of Voluntary...

On October 20, 2020, the Treasury Department’s Office of Foreign Assets Control (“OFAC”) announced that it had reached a $4.1 million settlement with Berkshire Hathaway, Inc., the multinational conglomerate holding company...more

CFIUS Issues 2018 Annual Report And Publishes Proposed Rule To Change Mandatory Filing Requirement For Critical Technologies

The Committee on Foreign Investment in the United States (“CFIUS”) had a busy week last week. The Department of the Treasury, which chairs CFIUS, released its Annual Report for 2018 and additional statistics for 2019 that...more

CFIUS Filing Fees Go Into Effect Today

On April 27, 2020, the Department of the Treasury issued an interim rule establishing a filing fee for certain transactions filed with the Committee on Foreign Investment in the United States (“CFIUS”). The fees only apply to...more

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