News & Articles

FinCEN Permanently Ends BOI Reporting for U.S. Companies and U.S. Persons Under the Corporate Transparency Act 

On August 11, 2026, the Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule permanently removing the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) under the Corporate Transparency Act (CTA). FinCEN states that U.S. companies are now exempt from BOI reporting requirements and no longer need to file BOI reports. The final rule also relieves U.S. persons from providing BOI to reporting companies and from updating or correcting information previously submitted to obtain a FinCEN identifier. For many domestic businesses, this marks a significant compliance shift—but foreign entities registered to do business in the United States may still have BOI obligations.

What Changed? 

FinCEN’s final rule makes permanent the relief first announced in the March 2025 interim final rule. Under the final rule, U.S. companies are exempt from BOI reporting requirements and therefore are no longer required to file BOI reports. Reporting companies also do not need to report BOI for U.S. person beneficial owners or U.S. person company applicants, and U.S. persons do not need to provide BOI to reporting companies. 

FinCEN also announced that U.S. persons with FinCEN identifiers are not required to update or correct the information they previously submitted to FinCEN. This is important for individuals who filed BOI information before the rule changed and who otherwise may have expected ongoing update obligations.

Who Still Has BOI Reporting Obligations? 

The final rule does not eliminate […]

DOJ Seeks to Vacate IEEPA Refund Injunctions 

Why Importers Who Haven’t Filed Suit Have the Most at Stake 

On August 10, 2026, the Department of Justice filed its opening brief in the consolidated Federal Circuit appeal challenging the Court of International Trade’s universal injunctions governing IEEPA duty refunds. The government’s own brief concedes that those injunctions now matter to exactly one group: importers with finally liquidated entries who have not filed suit. If the Federal Circuit vacates, that group has no administrative path to a refund, because CBP has told the court it lacks statutory authority to reliquidate finally liquidated entries on its own initiative. 

Key Takeaways 

  • The government filed its opening brief on August 10, 2026 in Federal Circuit Nos. 2026-1895, -1897, and -1899, appealing the CIT’s April 17, 2026 universal injunctions entered by Judge Richard K. Eaton. 
  • The government does not contest importer-specific reliquidation orders. It has stated it intends to comply with them and has not appealed the hundreds already entered. 
  • By the government’s own framing, the universal injunctions retain force only as to IEEPA refunds on finally liquidated entries belonging to importers who have not sued. 
  • CBP’s position is that Congress gave it no authority to reliquidate a finally liquidated entry absent a timely protest or reliquidation within 90 days of […]
By |2026-08-12T07:47:09-04:00August 12, 2026|Uncategorized|0 Comments

$5.15 Million Settlement Highlights Growing Customs Enforcement Under the False Claims Act

Short summary: A Taiwanese manufacturer has agreed to pay $5.15 million to resolve allegations that it violated the False Claims Act by underpaying customs duties on imported goods. According to the Department of Justice, the company used improper customs practices to reduce duties owed to CBP, resulting in significant lost tariff revenue. The settlement underscores the federal government’s continued focus on customs enforcement and the growing use of the False Claims Act to pursue alleged duty evasion. 


The U.S. Department of Justice recently announced that a Taiwan-led manufacturer agreed to pay $5.15 million to resolve allegations under the False Claims Act and related administrative claims involving customs duties owed on imported goods. While the company did not admit liability, the settlement serves as another reminder that customs compliance remains a significant enforcement priority for the federal government. 

The Case – What Happened 

According to the DOJ, the alleged conduct went well beyond a simple classification error. The government alleged that the company used multiple methods over several years to reduce the customs duties it owed on imports. Specifically: 

  • Country of Origin Misrepresentations: From July 2018 through January 2022, Everlight allegedly knowingly misrepresented the country of origin on Chinese-manufactured LEDs. Everlight knew these products were manufactured in China, and then transshipped to Taiwan, before shipping them to the U.S.  Everlight allegedly misrepresented to CBP that the products originated in Taiwan rather […]

New Section 201 Safeguard Tariffs on Quartz Surface Products 

Short summary: President Trump’s new Section 201 safeguard measure establishes a four-year tariff-rate quota (TRQ) on imports of quartz surface products beginning August 15, 2026. While annual quota volumes gradually increase over the life of the measure, importers may face safeguard duties of up to 50% once quarterly quota allocations are exhausted, making careful planning essential.  

On July 31, 2026, President Trump issued a proclamation imposing a Section 201 safeguard measure on imports of quartz surface products (QSP). The measure takes the form of a four-year tariff-rate quota (TRQ) and applies to goods entered, or withdrawn from warehouse for consumption, on or after 12:01 a.m. Eastern Time on Saturday, August 15, 2026.   

If you import QSP, including countertops, backsplashes, vanity tops, bar tops, work tops, tabletops, flooring, wall facing, shower surrounds, fireplace surrounds, mantels, and tiles, this measure will likely affect your imports.  

How the Tariff-Rate Quota Works

A TRQ is not a flat tariff. A set volume of covered merchandise may enter each quota year at a lower in-quota rate under the new HTSUS heading 9903.45.30. Once that volume is exhausted, additional entries pay a substantially higher over-quota rate under new heading 9903.45.31.

The annual volume is divided into four equal quarterly tranches. Any unused portion of a quarterly tranche carries forward into the following quarter, and CBP is required to add the unused quantity to the next quarter’s total no later than 14 days after the prior quarter […]

By |2026-08-10T10:14:31-04:00August 8, 2026|tariffs|0 Comments

Breaking Trade News: IEEPA Refunds Update, 301 Lawsuit, $5M FCA Settlement

This week’s recap of the latest customs and international trade news: 

Customs and Border Protection (CBP)        

  • CBP filed an update with the CIT in the IEEPA refunds case, stating that nearly $130 billion in potential and certified refunds have been accepted for processing via CAPE, and over 5 million entries failed entry level validations. 
  • CBP issued guidance via CSMS message regarding how to electronically remit payment for increases in duties, taxes and fees from a post-summary correction. Filers will not be able to pay in check or cash beginning Aug. 5. 
  • CBP officers from the George Bush Intercontinental Airport seized nearly $4 million in counterfeit goods, including fake MLB and Nike apparel, Louis Vuitton bags, Cartier sunglasses, and Jaguar Land Rover computer systems.

Courts      

  • A group of 25 states led by Oregon, Arizona and California filed a lawsuit at the CIT challenging the Section 301 forced labor tariffs as a violation of the Administrative Procedure Act, alleging that USTR’s investigation was rushed and failed to address comments.  
  • Customs broker Forrest Xu filed a complaint with the CIT arguing that CBP deactivated his broker entry filer code without due process.   

Department of Justice  

  • Everlight […]
By |2026-08-07T10:21:27-04:00August 7, 2026|news, Snapshot|0 Comments
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