1. Home
  2. |Insights
  3. |Pay to Play: CFIUS Implementing Fees for Submissions of Voluntary Notices

Pay to Play: CFIUS Implementing Fees for Submissions of Voluntary Notices

Client Alert | 1 min read | 03.06.20

On March 4, 2020, the Department of Treasury released a proposed rule to implement section 1723 of the Foreign Investment Risk Review Modernization Act of 2018 (FIRRMA) and require filing fees on voluntary notices to the Committee on Foreign Investment in the United States (CFIUS) for transactions that exceed $500,000. No fee will be required for the abbreviated declarations, whether voluntary or mandatory. The proposal adopts a sliding fee structure from $750 to $300,000 based upon transaction value:

< $500,000

$0

> $500,000 but < $5 million

$750

> $5 million but < $50 million

$7,500

> $50 million but < $250 million

$75,000

> $250 million but < $750 million

$150,000

> $ 750 million

$300,000


Some issues for comment over the next thirty days include (1) impact of the fees on the calculus for assessing whether to submit a voluntary disclosure; (2) appropriateness of the proposed tiers; and (3) valuation of certain transactions where it cannot be readily determined from the total transaction price.

Contacts

Insights

Client Alert | 7 min read | 08.19.26

CMS’s Final Rule Bans Federal Medicaid Funding for Youth Gender-Affirming Care

On August 13, 2026, the Centers for Medicare and Medicaid Services (CMS) published its final rule banning the use of federal funds — through Medicaid and the Children’s Health Insurance Program (CHIP) — to pay for gender-affirming care for children and youth. The final rule takes effect October 13, 2026 (“Prohibition on Federal Medicaid and Children's Health Insurance Program Funding for Sex-Rejecting Procedures Furnished to Children”). While CMS finalized several key elements of its late-2025 proposed rule (Client Alert December 24, 2025), the proposed Medicare hospital Condition of Participation rule remains in proposed form....

View All Insights