Customs Proposes To Substantially Transform The Substantial Transformation Test
Client Alert | less than 1 min read | 08.08.08
By Notice of Proposed Rulemaking, 73 Fed. Reg. 43385 (July 25, 2008), Customs & Border Enforcement has proposed substituting, for many purposes including rulings under the Trade Agreements Act (TAA), a "tariff shift" approach for determining country of origin in lieu of the longstanding and subjective "case-by-case" approach to determining the place where "substantial transformation" occurred. Under the proposed rule, contractors selling products under the contracts subject to the TAA would have to reevaluate their products under the rigid, pre-established formulaic tariff shift analysis to ensure products with significant non-designated country content qualify for sale to the federal government.
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Client Alert | 7 min read | 01.30.26
CMS Proposes CY 2027 Growth Rate and Changes to Risk Adjustment for Medicare Parts C and D
On January 26, 2026, the Centers for Medicare and Medicaid Services (CMS) circulated the Calendar Year (CY) 2027 Advance Notice to communicate proposed changes to Medicare Advantage (MA) capitation rates and Parts C and D payment policies. The changes are expected to be finalized in April 2026 but may be delayed. The following is a summary of the most significant proposals, with further details below:
Client Alert | 4 min read | 01.30.26
Optimum’s Shot Across the Bow: An Antitrust Challenge to Cooperation Agreements
Client Alert | 9 min read | 01.30.26
Client Alert | 7 min read | 01.29.26
ASEAN Digital Ministers' Meeting 2026: Spotlight on AI Cooperation in Asia's Rising Markets


