Off BLog

I'll be off blog for a bit. I'll be back. Give me a week or two.

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Scope: Aluminum Extrusions and Finished Goods Kits

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Understanding the scope of antidumping and countervailing duty orders is critically important for customs compliance professionals. It does a company no good whatsoever to find a low-cost producer of some product somewhere outside the U.S. only to later discover after importation that the merchandise is subject to an antidumping or countervailing duty. Given that antidumping and countervailing duties are often in excess of 30% and have been as high as 300%, this is a potentially serious concern. If Customs and Border Protection discovers the error and the error resulted from negligence, it can collect the unpaid duties plus penalties covering a five-year period. In some cases, that can be enough to bankrupt a small importer. Before we get into this case, let me dispel a common misunderstanding. CBP "flags" HTSUS classifications that are potentially subject to an ADD or CVD order. As a result, many brokers and importers manage AD and CVD compliance through tariff classificat...
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Mitigating 232 Penalties - I'm Back

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I realize I have been gone for a while. The first Trump Administration generated enough compliance work, litigation, and general chaos to keep me too busy and too stressed to do many things. One such thing was writing this blog. I did it mainly because I enjoy the process, and it forced me to stay on top of cases from the Court of International Trade and Court of Appeals for the Federal Circuit. Explaining those decisions in what I intend to be an approachable style helped me understand them. Over the past year, I have at times considered restarting the blog and never found the time or inspiration. Apparently, that has changed.  You may have noticed that the second Trump administration is off to a fast start in the trade space. We have new 10% tariffs on goods from China and 25% tariffs on an expanded list of steel and aluminum products. The 232 exclusion process has been shuttered. Reciprocal tariffs are being floated, as are potential tariffs on cars, pharmaceuticals, and chips....
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Vance Writing Competition

Andy Vance was a legendary figure in customs law and litigation. After a career at the Justice Department, he joined Barnes, Richardson & Colburn as a partner in the NY office. Sadly, I just missed the opportunity to work with him. The CITBA writing competition named in his honor is a great opportunity for J.D. and LL.M. students to demonstrate their interest in and knowledge of customs and international trade law. Plus, there is a monetary prize. Papers are due in June 2. See the details below. 2024-2025 Andrew P. Vance Memorial Writing Competition Call for Papers Wednesday, January 29, 2025   | Posted by CITBA Staff The Customs and International Trade Bar Association (CITBA) and Georgetown Law School are pleased to announce 2024-2025 Andrew P. Vance Memorial writing Competition. The competition is welcoming papers with an in-depth analysis of a current issue relevant to customs and international trade law. Entrants must be currently enrolled in a J.D. or L.L.M. program at any...
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