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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.


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Client Alert | 1 min read | 07.08.26

CAS Board Publishes Final Rule Rescinding CAS 404, 408, 409, and 4117

As part of its ongoing effort to conform the Cost Accounting Standards (“CAS”) to generally accepted accounting principles (“GAAP”), the CAS Board published a final rule rescinding CAS 408 (Accounting for costs of compensated personal absence) and CAS 411 (Accounting for acquisition costs of material).  The CAS Board also rescinded CAS 404 (Capitalization of tangible assets) and CAS 409 (Depreciation of tangible capital assets) but retained certain requirements of CAS 404 and 409, which will be located in new paragraphs of CAS 405 (Accounting for unallowable costs).  Specifically, the CAS Board retained the requirements currently located at CAS 404-50(d)(1), CAS 409-50(e)(5), CAS 409-50(j)(1), and CAS 409-50(j)(4), which the CAS Board explained are necessary to protect the Government’s interests.  Otherwise, the CAS Board determined that the requirements of CAS 404, 408, 409, and 411 overlapped with GAAP such that GAAP “may be applied reasonably as a substitute for CAS to support contract cost and pricing.”...

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