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Action Required for Importers Impacted by COVID-19

Client Alert | 1 min read | 03.24.20

USTR Seeks Comments on Removal of Tariffs on Certain Imports from China that Assist the U.S. Coronavirus Response

The Office of the U.S. Trade Representative (USTR) is seeking comments to remove Section 301 tariffs on certain imports from China that could help support the United States COVID-19 response. The USTR recently granted approximately 200 exclusions from the tariffs on China that covered personal protective equipment products, including medical masks, examination gloves, antiseptic wipes, and other medical-care related items, as a response to the COVID-19 outbreak.

The March 20, 2020, notice is seeking comments on whether a medical-care product is “needed to respond to the COVID-19 outbreak.” The Comment window will be open until at least June 25, 2020, and may be extended. 

Each comment specifically must identify the particular product of concern and explain precisely how the product relates to the response to the COVID-19 outbreak. This notice does not replace the current ongoing exclusion process. Comments may be submitted until June 25, 2020 (or until a later date if needed). However, to facilitate timely consideration, interested parties should submit comments as soon as possible.


Insights

Client Alert | 1 min read | 04.18.24

GSA Clarifies Permissibility of Upfront Payments for Software-as-a-Service Offerings

On March 15, 2024, the General Services Administration (GSA) issued Acquisition Letter MV-2024-01 providing guidance to GSA contracting officers on the use of upfront payments for acquisitions of cloud-based Software-as-a-Service (SaaS).  Specifically, this acquisition letter clarifies that despite statutory prohibitions against the use of “advance” payments outside of narrowly-prescribed circumstances, upfront payments for SaaS licenses do not constitute an “advance” payment subject to these restrictions when made under the following conditions:...