 The Daily Bugle is a free daily newsletter from Full Circle Compliance, containing changes to export/import regulations (ATF, Customs, NISPOM, EAR, FACR/OFAC, FTR/AES, HTSUS, and ITAR), plus news and events. Subscribe here for free subscription. Contact us for advertising inquiries and rates. |  |
| | - Commerce/BIS Amends EAR, Extends Validity of Temporary General License for Two ZTE Entities
| | | - Ex/Im Items Scheduled for Publication in Future Federal Register Editions
- Commerce/Census: “Tips on How to Resolve AES Fatal Errors”
- Commerce/BIS: (No new postings.)
- DoD/DSCA: “First Lead-Nation Procurement Case Signed”
- DoD/DSCA Posts SAMM and Policy Memoranda, Week 14-20 Aug
- State/DDTC Systems Undergo Scheduled Maintenance, 19-22 Aug
- State/DDTC Posts Name and Address Changes for Two Entities
| | | - Expeditors News: “IATA Announces Cargo XML Standard Accepted By CBP”
- ST&R Trade Report: “BIS Extends Suspension of Restrictions on Exports to Two ZTE Entities”
- ST&R Trade Report: “Dates and Deadlines: Classification, ACE/ITDS, Bonded Movements, Imports, Footwear”
| | | - A. Braumiller: “U.S. Implementation of WTO ITA Expansion Begins”
- B.H. Leeds: “Storing Export Controlled Data in the Cloud – What’s the Latest?”
- Gary Stanley’s ECR Tip of the Day
| | | - Friday List of Approaching Events
| | | - Rose Gottemoeller Moves to NATO
| | | - Bartlett’s Unfamiliar Quotations
- Are Your Copies of Regulations Up to Date? Latest Changes: ATF (15 Jan 2016), Customs (22 Mar 2016), DOD/NISPOM (18 May 2016), EAR (19 Aug 2016), FACR/OFAC (18 May 2016), FTR (15 May 2015), HTSUS (1 Jul 2016), ITAR (17 Aug 2016)
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EX/IM ITEMS FROM TODAY’S FEDERAL REGISTER |
1. Commerce/BIS Amends EAR, Extends Validity of Temporary General License for Two ZTE Entities (Source: Federal Register) [Excerpts.] 81 FR 55372-55374: Temporary General License: Extension of Validity * AGENCY: Bureau of Industry and Security, Commerce. * ACTION: Final rule. … * DATES: This rule is effective August 19, 2016 through November 28, 2016. The expiration date of the final rule published on March 24, 2016 (81 FR 15633) is extended until November 28, 2016. * FOR FURTHER INFORMATION CONTACT: Chair, End-User Review Committee, Office of the Assistant Secretary, Export Administration, Bureau of Industry and Security, Department of Commerce, Phone: (202) 482-5991, Email: ERC@bis.doc.gov. * SUPPLEMENTARY INFORMATION: BIS issued the March 24 final rule, and the June 28 final rule, in connection with a request to remove or modify the listing. The March 24 final rule, and the June 28 final rule, specified that the temporary general license was renewable if the U.S. Government determined, in its sole discretion, that ZTE Corporation and ZTE Kangxun were timely performing their undertakings to the U.S. Government and otherwise cooperating with the U.S. Government in resolving the matter which led to the two entities’ listing. At this time, the U.S. Government has decided to extend the temporary general license until November 28, 2016. In order to implement this U.S. Government decision, this final rule revises the temporary general license to remove the date of August 30, 2016, and substitute the date of November 28, 2016. This final rule makes no other changes to the EAR. … Dated: August 16, 2016. Kevin J. Wolf, Assistant Secretary for Export Administration. * * * * * * * * * * * * * * * * * * * *
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OTHER GOVERNMENT SOURCES |
2. Ex/Im Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register) * Justice; Alcohol, Tobacco, Firearms, and Explosives Bureau; NOTICES; Agency Information Collection Activities; Proposals, Submissions, and Approvals: Application and Permit for Importation of Firearms, Ammunition and Defense Articles [Publication Date: 22 August 2016.] * U.S. Customs and Border Protection; RULES; Investigations of Claims of Evasions of Antidumping and Countervailing Duties [Publication Date: 22 August 2016.] * * * * * * * * * * * * * * * * * * * *
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3 . Commerce/Census: “Tips on How to Resolve AES Fatal Errors” When a shipment is filed to the AES, a system response message is generated and indicates whether the shipment has been accepted or rejected. If the shipment is accepted, the AES filer receives an Internal Transaction Number (ITN) as confirmation. However, if the shipment is rejected, a Fatal Error notification is received. To help you resolve AES Fatal Errors, here are some tips on how to correct the most frequent errors that were generated in AES for this month. Fatal Error Response Code: 624 – Narrative: Schedule B/ HTS Number Outdated – Cannot Be Used – Reason: The Schedule B/ HTS Number reported is no longer valid in AES. – Resolution: The Schedule B/ HTS Number reported on an EEI cannot be outdated (i.e., expired). Compare the Estimated Date of Export to the Begin and End date of the Schedule B/HTS Number reported. Verify the Schedule B/HTS Number, correct the shipment and resubmit. To view the Schedule B Search Engine please go here. Fatal Error Response Code: 649 – Narrative: Quantity 1 Cannot Exceed Shipping Weight – Reason: Shipping Weight is reported in kilograms. When the Unit of Measure 1 requires kilograms, the first net quantity (Quantity 1) cannot exceed the Shipping Weight. Ensure the Shipping Weight includes the weight of the packaging materials. – Resolution: The first net quantity (Quantity 1) in kilograms cannot exceed the Shipping Weight in kilograms. Verify the Quantity 1 and Shipping Weight, correct the shipment and resubmit. For a complete list of Fatal Error Response Codes, their reasons, and resolutions, see Appendix A – Commodity Filing Response Messages. It is important that AES filers correct Fatal Errors as soon as they are received in order to comply with the Foreign Trade Regulations. These errors must be corrected prior to export for shipments filed predeparture and as soon as possible for shipments filed postdeparture, but not later than five calendar days after departure. For further information or questions, contact the U.S. Census Bureau’s Data Collection Branch. – Telephone: (800) 549-0595, select option 1 for AES. * * * * * * * * * * * * * * * * * * * *
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5 . DoD/DSCA: “First Lead-Nation Procurement Case Signed” The Department of State Bureau of Political-Military Affairs and Defense Security Cooperation Agency (DSCA) have announced the signing of the first Foreign Military Sales (FMS) case under the new Lead-Nation Procurement Initiative as part of a series of improvements to be made to FMS processes as outlined in DSCA’s strategic plan – DSCA Vision 2020. The FMS case, signed by the Baltic nations of Latvia, Lithuania, and Estonia, involves the sharing of costs associated with the hosting of a senior U.S. Army officer at the Baltic Defence College located in Tartu, Estonia. Established in 1998, the Baltic Defence College serves as a Professional Military Education (PME) institution for senior military leaders of the Baltic nations as well as other NATO Allies. The three NATO Allies agreed in 2015 that the addition of a U.S. Army senior officer to serve as a course director would add a new layer and further enhance the already-strong relationships between the United States, Latvia, Lithuania, and Estonia. The Lead-Nation Procurement Initiative is intended to support sales to a NATO organization or NATO country with subsequent retransfer to an identified group of NATO countries (currently a two-year pilot program). Lead-nation procurements will be supported by retransfer arrangements designed to permit flexible sharing among the identified group of participants while maintaining accountability and adhering to statutory reporting requirements. * * * * * * * * * * * * * * * * * * * *
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| 7. State/DDTC Systems Undergo Scheduled Maintenance, 19-22 Aug Industry users may experience availability issues for DDTC systems, including DTrade and EFS, from 6:30PM (EST) Friday August 19 through 6:00AM (EST) Monday August 22 due to scheduled system maintenance. * * * * * * * * * * * * * * * * * * * *
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| 8. State/DDTC Posts Name and Address Changes for Two Entities – Tactical Products Group, LLC Changes Address – Thales-Raytheon Systems Company SAS Changes Name to Thales Air Operations SAS Acquisition * * * * * * * * * * * * * * * * * * * *
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| On August 8, 2016 the International Air Transport Association (IATA) released a press release announcing that U.S. Customs and Border Protection (CBP) will be adopting IATA’s Cargo-XML messaging standard. The Cargo-XML is used on cross-border export shipments to collect advance data. With CBP utilizing the same messaging system, this will allow for more efficient communication between IATA and CBP. According to the notice, “CBP is working to reduce the considerable number of Electronic Data Interchange (EDI) message formats currently supported to process international import, export cargo and cargo release information.” CBP will begin using the new standards within a few months. The full release can be accessed here. * * * * * * * * * * * * * * * * * * * * |
10. ST&R Trade Report: “BIS Extends Suspension of Restrictions on Exports to Two ZTE Entities” The Bureau of Industry and Security has extended from Aug. 30 to Nov. 28 the expiration date of a temporary general license allowing exports of goods subject to the Export Administration Regulations from the U.S. to ZTE Corporation (Zhongxing Telecommunications Equipment Corporation) and ZTE Kangxun Telecommunications Ltd. Restrictions on such exports had been imposed March 8 when BIS placed these entities (and two others) on the Entity List following its determination that they were involved in a scheme to establish, control and use a series of shell companies to illicitly reexport controlled items to Iran. BIS subsequently issued a temporary general license that suspended these restrictions and restored the license requirements, license review policies and license exceptions under the EAR that applied prior to March 8 to exports, reexports and transfers (in-country) to these two entities. BIS has said that this license may be renewed if it determines that these entities are timely performing their undertakings to the U.S. government and otherwise cooperating in resolving the matter. For the other two entities (Beijing 8-Star and ZTE Parsian) there continues to be a license requirement for all items subject to the EAR and a license review policy of presumption of denial. The license requirement applies to any transaction in which items are to be exported, reexported or transferred (in-country) to either of these entities or in which they act as purchaser, intermediate consignee, ultimate consignee or end-user. In addition, no license exceptions are available for exports, reexports or transfers (in-country) to these entities. Click here to access a list of frequently-asked questions about these restrictions and their impact. * * * * * * * * * * * * * * * * * * * * |
11. ST&R Trade Report: “Dates and Deadlines: Classification, ACE/ITDS, Bonded Movements, Imports, Footwear” Following are highlights of regulatory effective dates and deadlines and federal agency meetings coming up in the next week. – Aug. 22: deadline for comments to Treasury on proposed rule to facilitate use of ITDS for imports of alcohol and tobacco products – Aug. 25: deadline for comments to EPA on chemical import information collection
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COMMENTARY |
| * Author: Adrianne Braumiller, Esq., Braumiller Law Group, PPLC, Adrienne@BraumillerLaw.com. In July, the Office of the United States Trade Representative (USTR) announced it has begun the process of implementing the expansion of the World Trade Organization (WTO) Information Technology Agreement (ITA). The process will be completed over the next 3 years. Once fully implemented, American technology exports will be freed from over $180 billion in tariffs annually. Globally, the WTO estimates that once the ITA is fully implemented by all signatories, approximately $1.3 trillion in tariffs will be removed. It has further been predicted that this will result in an annual increase of global gross domestic product of approximately $190 billion. Canada also announced in July that it has initiated implementation of the ITA expansions. These implementations follow the agreement reached in December of last year at the 10th WTO Ministerial in Nairobi, Kenya to begin implementation of the ITA expansion in July 2016. This agreement and its implementation are significant in that it is the first major tariff cutting agreement that the WTO has reached in 19 years. The agreement is already being hailed as a success by both developed and developing countries who view it as beneficial to their economies. In December 1996, 29 countries concluded the original ITA. Since that time there has been major growth in the international trade of technology products (almost tripling to $4 trillion annually). However, this is the first the time the ITA has been revised. This expansion covers 201 products. The number of participants to the ITA has also grown with the revision from 29 countries in 1996 to 82 countries today. These 82 countries represent 97% of international trade in information technology products. Significantly, the participants’ WTO schedules of concessions include ITA concessions, which means the ITA expansion is on a most-favored nation (MFN) basis. Therefore, even countries who are not a part of the ITA expansions may benefit from the tariff elimination. The ITA expansion also covers a broad range of products. It eliminates tariffs on an additional 201 products, which account for 7% of international trade. According to the WTO, the ITA expansion “covers new generation semi-conductors, semi-conductor manufacturing equipment, optical lenses, GPS navigation equipment, and medical equipment such as magnetic resonance imaging products and ultra-sonic scanning apparatus.” Other products include printer ink cartridges, headphones, video games consoles, and video cameras. Those seeking more information on the US implementation of the ITA expansion can refer here to the presidential proclamation issued on June 30, 2016. The proclamation details modifications to the “tariff categories and rates of duty set forth in the Harmonized Tariff Schedule (HTS).” Once fully implemented, the ultimate impact to American business is that they will no longer pay duties on imports of the 201 ITA products or be subject to duties when exporting the 201 ITA products to other ITA participating countries. * * * * * * * * * * * * * * * * * * * *
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| * Author: Bruce H. Leeds, Esq., Braumiller Law Group, PPLC, Bruce@BraumillerLaw.com. It is common these days for individuals and companies to store data in the “cloud”, which means that a server, or sets of servers located here, there, and everywhere are connected via the Internet. Is there a problem if that data is export controlled? Example 1 – A company has technical data controlled under the International Traffic in Arms Regulations (ITAR). It wants to store that data on a server located outside the U.S. Is that OK? Example 2 – A company has technology controlled under the Export Administration Regulations. It is currently stored on a server in the U.S., however the cloud storage service wants to move it to a foreign server. Is that permissible? Will any of these transactions require an export license or U.S. Government approval? Will the companies get in trouble if they try? Let’s take a look. First: Can storing data on a server outside the U.S. be considered an “export?” Under the recently revised definition in the EAR, “export” means, among other things, “An actual shipment or transmission out of the United States, including the sending or taking of an item out of the United States, in any manner.” “Item” in this case can include controlled information and data. The regulatory agencies have consistently interpreted “export” very broadly. Pretty much any way that a controlled article or data can wind up in the hands of a foreign person is considered an export. In fact, a foreign person having access to data and information stored on a server in the U.S. would also be an export. So, if placing controlled data on a server in a foreign country, or allowing a foreign person in the U.S. to have access to that data it is deemed an export. What do the regulations and interpretations say the data owner has to do to make it legal? Or should they just forget about cloud storage altogether? On June 2, 2016 the Bureau of Industry & Security published a Final Rule in the Federal Register that contained several new definitions and interpretations. This rule, which becomes effective on Sept. 1, 2016, establishes a “carve out” for transmissions of controlled data within a cloud service infrastructure requiring what is defined as “end-to-end” encryption of the data. This means that “data eligible for the carve-out must by definition be encrypted before crossing any national boundary, and must remain encrypted at all times while being transmitted from one security boundary to another.” Any data sent to a cloud server outside the U.S., or moved from a U.S. server to a foreign server, or potentially accessed by a foreign person inside or outside the U.S. must be appropriately encrypted before crossing an international border (or before any potential access by a foreign person). The means of decrypting the data cannot be provided to any third party before reaching the recipient. The change to the EAR added some further requirements for cloud storage of controlled technology: (1) The technology must be unclassified (2) It must be secured using cryptographic modules compliant with FIPS 140-2*, supplemented by software implementation, key management and other procedures and controls (3) The technology cannot be stored in a country subject to a U.S. arms embargo (EAR Country Group D:5 or ITAR §126.1) or in Russia. * Federal Information Processing Standard Publication 140-2, a U.S. Government security standard used to accredit cryptographic modules. What about ITAR rules for cloud storage of technical data? On the same day that BIS published the Final Rule in the Federal Register, DDTC published a corresponding Interim Final Rule with revisions to definitions in the ITAR. This rule also becomes effective on Sept. 1, 2016. It was an interim rule because DDTC would accept further comments until July 5, 2016. The DDTC rule did not specifically cover cloud storage of technical data; however its revised definitions of “export”. “re-export” and “release” certainly encompass transfers of technical data to, or within, foreign cloud servers. Although the Interim Final Rule did not address cloud storage, Advisory Opinion letter GC 0317-14 of May 27, 2014 set forth a standard very similar to that published by BIS. The letter stated that “tokenization” (the process of substituting a sensitive data element with a non-sensitive equivalent, referred to as a token, that has no extrinsic or exploitable meaning or value) could be used to process controlled technical data even to servers located outside the U.S., provided that certain requirements were met. They included: – The data must be received and used only by U.S. persons who are U.S. Government employees or employees of a U.S. corporation through all phases of the transfer including transmission, storage and receipt; – The sender must also be a U.S. person who is an employee of the U.S. Government or a U.S. corporation; – Movement of classified data must be in accordance with the Department of Defense National Industrial Security Program Operating Manual. The General Correspondence letter actually said the data fell under the ITAR exemption in 125.4(b)(9) and that the limitations in §125.1 will apply to such storage and transfers. This means that any export or re-export from the country of ultimate end use or authorized foreign end user (as specified on a license, exemption or agreement), or transfer to a foreign person, will require prior DDTC approval. Thus it appears that controlled technical data and technology can potentially be stored or moved to a cloud server outside the U.S., but all requirements in the ITAR and EAR must first be satisfied. It is 2016. Do you know where your data is? * * * * * * * * * * * * * * * * * * * *
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14. Gary Stanley’s ECR Tip of the Day (Source: Defense and Export-Import Update; available by subscription from gstanley@glstrade.com ) * Author: Gary Stanley, Esq., Global Legal Services, PC, (202) 352-3059, gstanley@glstrade.com The following five types of facts determine your obligations under the EAR and will be of help to you in reviewing these steps: (1) What is it? What an item is, for export control purposes, depends on its classification, which is its place on the Commerce Control List (see part 774 of the EAR). (2) Where is it going? The country of ultimate destination for an export or reexport also determines licensing requirements (see parts 738 and 774 of the EAR concerning the Country Chart and the Commerce Control List). (3) Who will receive it? The ultimate end-user of your item cannot be a bad end-user. See General Prohibition Four (Denial Orders) in §736.2(b)(4) and parts 744 and 764 of the EAR for a reference to the list of persons you may not deal with. (4) What will they do with it? The ultimate end-use of your item cannot be a bad end-use. See General Prohibition Five (End-Use End-User) in section 736.2(b)(5) and part 744 of the EAR for general end-use and end-user restrictions. (5) What else do they do? Conduct such as contracting, financing, and freight forwarding in support of a proliferation project (as described in section 744.6 of the EAR) may prevent you from dealing with someone. * * * * * * * * * * * * * * * * * * * *
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EX/IM TRAINING EVENTS & CONFERENCES |
15 . Friday List of Approaching Events * Oct 3-6: Amsterdam NL: “United States Export Control (EAR/OFAC/ITAR) (for EU and other non-US Companies);” ECTI;jessica@learnexportcompliance.com; 540-433-3977 * Oct 9-11: Grapevine TX: “DFW Fall Conference;” ICPA * Oct 19: London; “Control List Classification – Dual Use;” UK/BIS Export Control Organisation; denise.carter@bis.gsi.gov.uk * Oct 24-25: Arlington VA; “2016 Fall Conference;” Society for International Affairs; admin@siaed.org * Oct 31-Nov 3: Wash DC; “US Export Controls Seminar;” ECTI; jessica@learnexportcompliance.com; 540-433-3977 * Nov 2: Chicago; “AES Compliance Seminar;” Dept. of Commerce/ Census & M-Palm; shawn@m-palm.com * Nov 3-4: Amsterdam International Trade & Compliance Conference; Email Claudia Wehmeijer to Request an Invitation; Baker McKenzie * * * * * * * * * * * * * * * * * * * *
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| EX/IM MOVERS & SHAKERS |
16 . Rose Gottemoeller Moves to NATO Rose Gottemoeller, current Under Secretary of State for Arms Control and International Security, has been named as NATO Deputy Secretary General, replacing Alexander Vershbow. She will take the position on Oct. 1, 2016.
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| EDITOR’S NOTES |
17. Bartlett’s Unfamiliar Quotations (Source: Editor)
“Even victors are by victories undone.”
– John Dryden (1631-1700, was an English poet, literary critic, translator, and playwright who was made England’s first Poet Laureate in 1668.)
“To keep your marriage brimming, With love in the loving cup, Whenever you’re wrong, admit it; Whenever you’re right, shut up.”
– Ogden Nash (Frederic Ogden Nash, 1902-1971, was an American poet well known for his light verse.)
Friday funnies:
Bob, a 70-year-old, extremely wealthy widower, shows up at the Country Club with a breathtakingly gorgeous, 25-year-old woman who wows all the gentlemen with her sex appeal and charm, and hangs over Bob’s arm and listens intently to his every word. His buddies at the club are all aghast. At their first chance, they corner him and ask, “Bob, how’d you get the trophy girlfriend?” Bob replied, “Girlfriend? She’s my wife!” They’re knocked over, but continue to ask: “So, how’d you persuade her to marry you?” “I lied about my age,” Bob replied. “What? Did you tell her you were only 50?” Bob smiled and said, “No, I told her I was 90.”
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18. Are Your Copies of Regulations Up to Date?
(Source: Editor) The official versions of the following regulations are published annually in the U.S. Code of Federal Regulations (C.F.R.), but are updated as amended in the Federal Register. Changes to applicable regulations are listed below. – Last Amendment: 15 Jan 2016: 81 FR 2657-2723: Machineguns, Destructive Devices and Certain Other Firearms; Background Checks for Responsible Persons of a Trust or Legal Entity With Respect To Making or Transferring a Firearm – Last Amendment: 22 Mar 2015: 81 FR 15159: Customs and Border Protection’s Bond Program; Correction * DOD NATIONAL INDUSTRIAL SECURITY PROGRAM OPERATING MANUAL (NISPOM): DoD 5220.22-M
– Last Amendment: 18 May 2016: Change 2: Implement an insider threat program; reporting requirements for Cleared Defense Contractors; alignment with Federal standards for classified information systems; incorporated and canceled Supp. 1 to the NISPOM (Summary here.) * EXPORT ADMINISTRATION REGULATIONS (EAR): 15 CFR Subtit. B, Ch. VII, Pts. 730-774 – Last Amendment: 19 Aug 2016: 81 FR 55372-55374: Temporary General License: Extension of Validity – Last Amendment: 15 May 2015; 80 FR 27853-27854: Foreign Trade Regulations (FTR): Reinstatement of Exemptions Related to Temporary Exports, Carnets, and Shipments Under a Temporary Import Bond – HTS codes that are not valid for AES are available here. – The latest edition (9 Mar 2016) of Bartlett’s Annotated FTR (“BAFTR”), by James E. Bartlett III, is available for downloading in Word format. The BAFTR contains all FTR amendments, FTR Letters and Notices, a large Index, and footnotes containing case annotations, practice tips, and Census/AES guidance. Subscribers receive revised copies every time the FTR is amended. The BAFTR is available by annual subscription from the Full Circle Compliance website. BITAR subscribers are entitled to a 25% discount on subscriptions to the BAFTR. Please contact us to receive your discount code. – HTS codes for AES are available here . – HTS codes that are not valid for AES are available here. – Latest Amendment: 17 Aug 2016: 81 FR 54732-54737: Amendment to the International Traffic in Arms Regulations: Procedures for Obtaining State Department Authorization To Export Items Subject to the Export Administration Regulations; Revision to the Destination Control Statement; and Other Changes – The only available fully updated copy (latest edition 17 Aug 2016) of the ITAR is contained in Bartlett’s Annotated ITAR (“BITAR”), by James E. Bartlett III. The BITAR contains all ITAR amendments to date, plus a large Index, and over 700 footnotes containing case annotations, practice tips, DDTC guidance, and explanations of errors in the official ITAR text. Subscribers receive updated copies of the BITAR in Word by email, usually revised within 24 hours after every ITAR amendment. The BITAR is THE essential tool of the ITAR professional. The BITAR is available by annual subscription from the Full Circle Compliance website. BAFTR subscribers receive a 25% discount on subscriptions to the BITAR, please contact us to receive your discount code. * * * * * * * * * * * * * * * * * * * *
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| * The Ex/Im Daily Update is a publication of FCC Advisory B.V., edited by James E. Bartlett III and Alexander Bosch, and emailed every business day to approximately 7,500 readers of changes to defense and high-tech trade laws and regulations. We check the following sources daily: Federal Register, Congressional Record, Commerce/AES, Commerce/BIS, DHS/CBP, DOJ/ATF, DoD/DSS, DoD/DTSA, State/DDTC, Treasury/OFAC, White House, and similar websites of Australia, Canada, U.K., and other countries and international organizations. Due to space limitations, we do not post Arms Sales notifications, Denied Party listings, or Customs AD/CVD items. * INTERNET ACCESS AND BACK ISSUES: The National Defense Industrial Association (“NDIA”) posts the Daily Update on line, and maintains back issues since August, 2009 here. * RIGHTS & RESTRICTIONS: This email contains no proprietary, classified, or export-controlled information. All items are obtained from public sources or are published with permission of private contributors, and may be freely circulated without further permission. Any further use of contributors’ material, however, must comply with applicable copyright laws. * CAVEAT: The contents cannot be relied upon as legal or expert advice. Consult your own legal counsel or compliance specialists before taking actions based upon news items or opinions from this or other unofficial sources. If any U.S. federal tax issue is discussed in this communication, it was not intended or written by the author or sender for tax or legal advice, and cannot be used for the purpose of avoiding penalties under the Internal Revenue Code or promoting, marketing, or recommending to another party any transaction or tax-related matter.
* SUBSCRIPTIONS: Subscriptions are free. Subscribe by completing the request form on the Full Circle Compliance website. * TO UNSUBSCRIBE: Use the Safe Unsubscribe link below. |
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