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It’s a Plane: Significant Modifications do not Result in Substantial Transformation

Client Alert | 1 min read | 03.13.17

On March 10, 2017, U.S. Customs and Border Protection published a final determination under the Trade Agreements Act that the country of origin of a Brazilian-manufactured military cargo airplane would remain Brazil, even after the aircraft undergoes significant conversion into a civil fire-fighting aircraft within the United States. According to CBP, the U.S.-origin changes to the aircraft—which include removing and adding various systems and components to install fire suppression capability—are not sufficient to change the aircraft’s “fundamental identity” and thus, do not constitute “substantial transformation.” The CBP emphasized that the aircraft would maintain its “most important” systems, the “basic structural integrity and the aerodynamics of the aircraft” would remain unchanged, and there was no evidence to demonstrate meaningful changes to the aircraft’s power, speed and range, or to the electronics and instruments used to fly the plane.

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Client Alert | 9 min read | 08.02.26

The 2026 ICC Arbitration Rules: A New Era

The International Chamber of Commerce (ICC) has released its revised 2026 Arbitration Rules (the 2026 Rules), which entered into force on 1 June 2026. The 2026 Rules apply to any arbitration commenced on or after 1 June 2026, unless the parties have agreed otherwise. The revisions were driven by increased competition among arbitral institutions—illustrated by recent amendments to the Singapore International Arbitration Centre (SIAC) Rules in August 2025 and the anticipated update to the London Court of International Arbitration (LCIA) Rules....