Pay-to-Play 2: CFIUS Filing Fees Go Into Effect May 1, 2020
Client Alert | 1 min read | 04.28.20
The Committee on Foreign Investment in the US (CFIUS) has announced an Interim Final Rule requiring payment of filing fees in connection with any Joint Voluntary Notices submitted on or after May 1, 2020 for “covered transactions” under 31 C.F.R. Part 800 or for “covered real estate transactions” under Part 802. The Interim Final Rule adopts, without change, the sliding scale fee structure as initially proposed, but in light of the COVID-19 pandemic, will continue to accept comments until June 1, 2020.
The fee schedule is:
Total Transaction Value |
Filing Fee |
|
< $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 |
CFIUS rejected comments seeking to limit the transaction value to just the value of the U.S. business and denied concerns that the lack of any fee for submission of mandatory or voluntary declarations would provide a financial or administrative incentive for CFIUS to fail to conclude action under Section 721 of the Defense Production Act in evaluating such declarations.
Contacts
Insights
Client Alert | 7 min read | 10.29.26
On 8 October 2026, Crowell & Moring, King's College London, and the Competition Law Center at George Washington University co-hosted the 7th EU Competition Law Conference at De Warande in Brussels. Mark Meador, Commissioner at the US Federal Trade Commission (FTC), delivered the opening keynote address, followed by four panels bringing together practitioners, regulators, academics, and in-house counsel to discuss the latest developments in EU, UK, and US competition law enforcement. Among other things, the panels examined algorithmic pricing; the European Commission's (Commission) new guidelines on exclusionary abuses under Article 102 TFEU (Article 102 Guidelines); the impact of dominant positions in merger reviews; and lessons from the enforcement of the Digital Markets Act (DMA) and the UK’s Digital Markets, Competition and Consumers Act.
Client Alert | 3 min read | 10.29.26
What University Licensors Should Learn From TexasLDPC v. Broadcom
Client Alert | 2 min read | 10.28.26
Debriefing to Dead Briefing: How to Avoid Dismissal by Identifying “Required” Debriefings
Client Alert | 7 min read | 10.27.26
