 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. |  |
| | - DHS/CBP Seeks Comments on Form 3499, Application and Approval To Manipulate, Examine, Sample or Transfer Goods
- DHS/CBP Seeks Comments on Foreign Assembler’s Declaration
- DHS/CBP Seeks Comments on Form 3485, Lien Notice
- DHS/CBP Seeks Comments on 1300, Vessel Entrance or Clearance Statement
- DHS/CBP Announces Successful Conclusion of NCAP Test Concerning Submission of FSIS Data in ACE
| | | - Ex/Im Items Scheduled for Publication in Future Federal Register Editions
- Commerce/BIS: (No new postings.)
- State/DDTC: (No new postings.)
| | | - ST&R Trade Report: “Dates and Deadlines: Informed Compliance Letters, ACE Protests, EAR Licenses, Classification”
- ST&R Trade Report: “Foreign Policy-Based Export Controls Subject of Annual BIS Review”
| | | - Friday List of Approaching Events
| | | - Bartlett’s Unfamiliar Quotations
- Are Your Copies of Regulations Up to Date? Latest Changes: ATF (15 Jan 2016), Customs (26 Aug 2016), DOD/NISPOM (18 May 2016), EAR (7 Sep 2016), FACR/OFAC (18 May 2016), FTR (15 May 2015), HTSUS (30 Aug 2016), ITAR (8 Sep 2016)
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EX/IM ITEMS FROM TODAY’S FEDERAL REGISTER |
1. DHS/CBP Seeks Comments on Form 3499, Application and Approval To Manipulate, Examine, Sample or Transfer Goods (Source: Federal Register) [Excerpts.] 81 FR 62519-62520: Agency Information Collection Activities: Application and Approval To Manipulate, Examine, Sample or Transfer Goods * AGENCY: U.S. Customs and Border Protection, Department of Homeland Security. * ACTION: 60-Day notice and request for comments; extension of an existing collection of information. … * DATES: Written comments should be received on or before November 8, 2016 to be assured of consideration. * ADDRESSES: All submissions received must include the OMB Control Number 1651-0006 in the subject box, the agency name. To avoid duplicate submissions, please use only one of the following methods to submit comments: (1) Email. Submit comments to: CBP_PRA@CBP.DHS.GOV, email should include OMB Control number in Subject. (2) Mail. Submit written comments to CBP PRA Officer, U.S. Customs and Border Protection, Office of Trade, Regulations and Rulings, Economic Impact Analysis Branch, 10th Floor, 90 K St. NE., Washington, DC 20229-1177. * FOR FURTHER INFORMATION CONTACT: Requests for additional PRA information should be directed to Paperwork Reduction Act Officer, U.S. Customs and Border Protection, Regulations and Rulings, Office of Trade, 90 K Street NE., 10th Floor, Washington, DC 20229-1177, or via telephone (202) 325-0123. Please note contact information provided here is solely for questions regarding this notice. Individuals seeking information about other CBP programs please contact the CBP National Customer Service Center at 877-227-5511, (TTY) 1-800-877-8339, or CBP Web site. For additional help please go here. * SUPPLEMENTARY INFORMATION: … – Title: Application and Approval to Manipulate, Examine, Sample or Transfer Goods. – OMB Number: 1651-0006. – Form Number: Form 3499. – Abstract: CBP Form 3499, “Application and Approval to Manipulate, Examine, Sample or Transfer Goods,” is used as an application to perform various operations on merchandise located at a CBP approved bonded facility. This form is filed by importers, consignees, transferees, or owners of merchandise, and is subject to approval by the port director. The data requested on this form identifies the merchandise for which action is being sought and specifies what operation is to be performed. This form may also be approved as a blanket application to manipulate goods for a period of up to one year for a continuous or repetitive manipulation. CBP Form 3499 is provided for by 19 CFR 19.8 and is accessible here. … Dated: September 2, 2016. Seth Renkema, Branch Chief, Economic Impact Analysis Branch, U.S. Customs and Border Protection. * * * * * * * * * * * * * * * * * * * *
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2. DHS/CBP Seeks Comments on Foreign Assembler’s Declaration (Source: Federal Register) [Excerpts.] 81 FR 62517-62518: Agency Information Collection Activities: Foreign Assembler’s Declaration * AGENCY: U.S. Customs and Border Protection, Department of Homeland Security. * ACTION: 60-Day notice and request for comments; extension of an existing collection of information. … * DATES: Written comments should be received on or before November 8, 2016 to be assured of consideration. * ADDRESSES: All submissions received must include the OMB Control Number 1651-0031 in the subject box, the agency name. To avoid duplicate submissions, please use only one of the following methods to submit comments: (1) Email. Submit comments to: CBP_PRA@CBP.DHS.GOV, email should include OMB Control number in Subject line. (2) Mail. Submit written comments to CBP PRA Officer, U.S. Customs and Border Protection, Office of Trade, Regulations and Rulings, Economic Impact Analysis Branch, 10th Floor, 90 K St NE., Washington, DC 20229-1177. * FOR FURTHER INFORMATION CONTACT: Requests for additional PRA information should be directed to Paperwork Reduction Act Officer, U.S. Customs and Border Protection, Regulations and Rulings, Office of Trade, 90 K Street NE., 10th Floor, Washington, DC 20229-1177, or via telephone (202) 325-0123, Please note contact information provided here is solely for questions regarding this notice. Individuals seeking information about other CBP programs please contact the CBP National Customer Service Center at 877-227-5511, (TTY) 1-800-877-8339, or CBP Web site. For additional help please go here. * SUPPLEMENTARY INFORMATION: … – Title: Foreign Assembler’s Declaration (with Endorsement by Importer). – OMB Number: 1651-0031. – Abstract: In accordance with 19 CFR 10.24, a Foreign Assembler’s Declaration must be made in connection with the entry of assembled articles under subheading 9802.00.80, Harmonized Tariff Schedule of the United States (HTSUS). This declaration includes information such as the quantity, value and description of the imported merchandise. The declaration is made by the person who performed the assembly operations abroad and it includes an endorsement by the importer. The Foreign Assembler’s Declaration is used by CBP to determine whether the operations performed are within the purview of subheading 9802.00.80, HTSUS and therefore eligible for preferential tariff treatment. 19 CFR 10.24(c) and (d) require that the importer/assembler maintain records for 5 years from the date of the related entry and that they make these records readily available to CBP for audit, inspection, copying, and reproduction. Instructions for complying with this regulation are posted on the CBP.gov Web site here. … Dated: September 6, 2016. Seth Renkema, Branch Chief, Economic Impact Analysis Branch, U.S. Customs and Border Protection. * * * * * * * * * * * * * * * * * * * *
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3. DHS/CBP Seeks Comments on Form 3485, Lien Notice (Source: Federal Register) [Excerpts.] 81 FR 62518-62519: Agency Information Collection Activities: Lien Notice * AGENCY: U.S. Customs and Border Protection, Department of Homeland Security. * ACTION: 60-Day Notice and request for comments; extension of an existing collection of information. … * DATES: Written comments should be received on or before November 8, 2016 to be assured of consideration. * ADDRESSES: All submissions received must include the OMB Control Number 1651-0012 in the subject box, the agency name. To avoid duplicate submissions, please use only one of the following methods to submit comments: (1) Email: Submit comments to: CBP_PRA@CBP.DHS.GOV, email should include OMB Control number in Subject line. (2) Mail: Submit written comments to CBP PRA Officer, U.S. Customs and Border Protection, Office of Trade, Regulations and Rulings, Economic Impact Analysis Branch, 10th Floor, 90 K St NE., Washington, DC 20229-1177. * FOR FURTHER INFORMATION CONTACT: Requests for additional PRA information should be directed to Paperwork Reduction Act Officer, U.S. Customs and Border Protection, Regulations and Rulings, Office of Trade, 90 K Street NE., 10th Floor, Washington, DC 20229-1177, or via telephone (202) 325-0123. Please note contact information provided here is solely for questions regarding this notice. Individuals seeking information about other CBP programs please contact the CBP National Customer Service Center at 877-227-5511, (TTY) 1-800-877-8339, or CBP Web site. For additional help please go here. * SUPPLEMENTARY INFORMATION: … – Title: Lien Notice. – OMB Number: 1651-0012. – Form Number: 3485. – Abstract: Section 564, Tariff Act of 19, as amended (19 U.S.C. 1564) provides that the claimant of a lien for freight can notify CBP in writing of the existence of a lien, and CBP shall not permit delivery of the merchandise from a public store or a bonded warehouse until the lien is satisfied or discharged. The claimant shall file the notification of a lien on CBP Form 3485, Lien Notice. This form is usually prepared and submitted to CBP by carriers, cartmen and similar persons or firms. The data collected on this form is used by CBP to ensure that liens have been satisfied or discharged before delivery of the freight from public stores or bonded warehouses, and to ensure that proceeds from public auction sales are distributed to the lienholder. CBP Form 3485 is provided for by 19 CFR 141.112, and is accessible here. … Dated: September 2, 2016. Seth Renkema, Branch Chief, Economic Impact Analysis Branch, U.S. Customs and Border Protection. * * * * * * * * * * * * * * * * * * * *
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4. DHS/CBP Seeks Comments on 1300, Vessel Entrance or Clearance Statement (Source: Federal Register) [Excerpts.] 81 FR 62517: Agency Information Collection Activities: Vessel Entrance or Clearance Statement * AGENCY: U.S. Customs and Border Protection, Department of Homeland Security. * ACTION: 60-Day Notice and request for comments; extension of an existing collection of information. … * DATES: Written comments should be received on or before November 8, 2016 to be assured of consideration. * ADDRESSES: All submissions received must include the OMB Control Number 1651-0019 in the subject box, the agency name. To avoid duplicate submissions, please use only one of the following methods to submit comments: (1) Email. Submit comments to: CBP_PRA@CBP.DHS.GOV, Include OMB Control Number in the Subject. (2) Mail. Submit written comments to CBP PRA Compliance Officer, U.S. Customs and Border Protection, Office of Trade, Regulations and Rulings, Economic Impact Analysis Branch, 10th Floor, 90 K St. NE., Washington, DC 20229-1177. * FOR FURTHER INFORMATION CONTACT: Requests for additional PRA information should be directed to Paperwork Reduction Act Officer, U.S. Customs and Border Protection, Regulations and Rulings, Office of Trade, 90 K Street NE., 10th Floor, Washington, DC 20229-1177, or via telephone (202) 325-0123, Please note contact information provided here is solely for questions regarding this notice. Individuals seeking information about other CBP programs please contact the CBP National Customer Service Center at 877-227-5511, (TTY) 1-800-877-8339, or CBP Web site. For additional help please go here. * SUPPLEMENTARY INFORMATION: … – Title: Vessel Entrance or Clearance Statement. – OMB Number: 1651-0019. – Form Number: CBP Form 1300. – Abstract: CBP Form 1300, Vessel Entrance or Clearance Statement, is used to collect essential commercial vessel data at time of formal entrance and clearance in U.S. ports. The form allows the master to attest to the truthfulness of all CBP forms associated with the manifest package, and collects information about the vessel, cargo, purpose of entrance, certificate numbers, and expiration for various certificates. It also serves as a record of fees and tonnage tax payments in order to prevent overpayments. CBP Form 1300 was developed through agreement by the United Nations Intergovernmental Maritime Consultative Organization (IMCO) in conjunction with the United States and various other countries. This form is authorized by 19 U.S.C. 1431, 1433, and 1434, and provided for by 19 CFR 4.7-4.9, and accessible here. … Dated: September 2, 2016. Seth Renkema, Branch Chief, Economic Impact Analysis Branch, U.S. Customs and Border Protection. * * * * * * * * * * * * * * * * * * * *
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5. DHS/CBP Announces Successful Conclusion of NCAP Test Concerning Submission of FSIS Data in ACE (Source: Federal Register) [Excerpts.] 81 FR 62515-62516: Conclusion of the National Customs Automation Program (NCAP) Test Concerning the Submission of Data Required by the Food Safety and Inspection Service (FSIS) in the Automated Commercial Environment (ACE) * AGENCY: U.S. Customs and Border Protection, Department of Homeland Security. * ACTION: General notice. * SUMMARY: This document announces the conclusion of the National Customs Automation Program (NCAP) test concerning the electronic transmission of certain import data required by the Food Safety and Inspection Service (FSIS) to the Automated Commercial Environment (ACE) using the Partner Government Agency (PGA) Message Set. U.S. Customs and Border Protection (CBP) has determined that the NCAP test has been a success, as ACE has proven capable of receiving and processing the data required by FSIS, and sharing that data with FSIS. Accordingly, this NCAP test will be concluded on October 11, 2016. CBP has made ACE the sole CBP-authorized electronic data interchange (EDI) system for most entry and entry summary filings, including entry and entry summary filings for meat, poultry and egg products regulated by FSIS. As a result, filers transmitting electronic import data required by FSIS with their electronic entry or entry summary must use ACE. * DATES: The NCAP test will conclude on October 11, 2016. * ADDRESSES: Comments concerning this notice and any aspect of this test may be submitted via email to Josephine Baiamonte, ACE Business Office (ABO), Office of Trade, at josephine.baiamonte@cbp.dhs.gov. * FOR FURTHER INFORMATION CONTACT: For CBP-related questions, contact Jeffrey Nii, Director, Inter-Agency Collaboration Division, Office of Trade, at jeffrey.c.nii@cbp.dhs.gov. * SUPPLEMENTARY INFORMATION: … This notice announces that CBP has determined that ACE is fully capable of accepting electronic entries transmitted to ACE with the PGA Message Set data required for FSIS-regulated meat, poultry, and egg products. The electronic transmission of this data to ACE expedites delivery of this data to FSIS, thereby providing the data to FSIS before the products arrive for inspection. This allows FSIS to more effectively track and control shipments and improve compliance. Having found this test to be successful, CBP hereby concludes the test, effective October 11, 2016. Dated: September 1, 2016. Brenda B. Smith, Executive Assistant Commissioner, Office of Trade. * * * * * * * * * * * * * * * * * * * *
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OTHER GOVERNMENT SOURCES |
6. Ex/Im Items Scheduled for Publication in Future Federal Register Editions
(Source: Federal Register) * Treasury; Foreign Assets Control Office; NOTICES; Blocking or Unblocking of Persons and Properties [Publication Date: 12 September 2016.] * * * * * * * * * * * * * * * * * * * *
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| Following are highlights of regulatory effective dates and deadlines and federal agency meetings coming up in the next week. – Sep 13: effective date of FDA final rule allowing stand-alone symbols on medical device labeling – Sep 16: deadline for comments to USDA on proposed changes to import requirements for sheep and goats * * * * * * * * * * * * * * * * * * * * |
10. ST&R Trade Report: “Foreign Policy-Based Export Controls Subject of Annual BIS Review” The Bureau of Industry and Security is seeking comments by Oct. 11 for its annual review of whether the foreign policy-based export controls in the Export Administration Regulations should be modified, rescinded, or extended from January 2017 to January 2018. Coverage of Controls. Foreign-policy based export controls apply to a range of countries, items, activities, and persons, including the following: – entities acting contrary to U.S. national security or foreign policy interests – certain general purpose microprocessors for military end-uses and military end-users – hot section technology for the development, production, or overhaul of commercial aircraft engines, components, and systems – encryption items – crime control and detection items – specially designed implements of torture – certain firearms and related items – regional stability items – equipment and related technical data used in the design, development, production, or use of certain rocket systems and unmanned air vehicles – chemical precursors and biological agents, associated equipment, technical data, and software – various chemicals included on the list of those controlled pursuant to the Chemical Weapons Convention – communication intercepting devices, software, and technology – maritime nuclear propulsion – certain foreign aircraft and vessels – exports and reexports to certain persons designated as proliferators of weapons of mass destruction – certain cameras to be used by military end-users or incorporated into a military commodity – countries designated as supporters of acts of international terrorism – certain entities in Russia – individual terrorists and terrorist organizations – certain persons designated by Executive Order 13315 (“Blocking Property of the Former Iraqi Regime, Its Senior Officials and Their Family Members”) – certain sanctioned entities – embargoed countries – U.S. and UN arms embargoes In addition, the EAR impose foreign policy-based export controls on certain nuclear-related commodities, technology, end-uses, and end-users. Criteria for Determining Whether to Continue Controls. Among the criteria considered in determining whether to extend U.S. foreign policy-based export controls are the following: – the likelihood that such controls will achieve their intended foreign policy purposes in light of other factors, including the availability from other countries of the goods, software, or technology proposed for such controls – whether the foreign policy objective of such controls can be achieved through negotiations or other alternative means – the compatibility of the controls with U.S. foreign policy objectives and overall U.S. policy toward the country subject to the controls – whether the reaction of other countries to the extension of such controls is not likely to render the controls ineffective in achieving the intended foreign policy objective or be counterproductive to U.S. foreign policy interests – the comparative benefits to U.S. foreign policy objectives versus the effect of the controls on U.S. export performance, the competitive position of the U.S. in the international economy and the international reputation of the U.S. as a supplier of goods and technology – the ability of the U.S. to effectively enforce the controls – the economic impact of proliferation controls Industry Information Sought. BIS is interested in industry information relating to the following. – the effect of foreign policy-based export controls on sales of U.S. products to third countries (i.e., those not targeted by sanctions), including the views of foreign purchasers or prospective customers regarding these controls – controls maintained by U.S. trade partners (e.g., the extent to which they have similar controls on goods and technology on a worldwide basis or to specific destinations) – licensing policies or practices by U.S foreign trade partners that are similar to U.S. foreign policy-based export controls, including license review criteria, use of conditions, and requirements for pre- and post-shipment verifications (preferably supported by examples of approvals, denials, and foreign regulations) – revisions to foreign policy-based export controls that would bring them more into line with multilateral practice – actions that would make multilateral controls more effective – the effect of foreign policy-based export controls on trade or acquisitions by the intended targets of the controls – the effect of foreign policy-based export controls on overall trade at the level of individual industrial sectors – how to measure the effect of foreign policy-based export controls on trade – the use of foreign policy-based export controls on targeted countries, entities, or individuals * * * * * * * * * * * * * * * * * * * * | |
EX/IM TRAINING EVENTS & CONFERENCES |
11 . 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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| EDITOR’S NOTES |
12. Bartlett’s Unfamiliar Quotations (Source: Editor)
Notable birthdays:
* Colonel Sanders (Harland David Sanders; 9 Sep 1890 – 16 Dec 1980; was an American businessman, best known for founding fast food chicken restaurant chain Kentucky Fired Chicken.)
– “I’ve got no idea when I am going to retire. Whenever they pick me up and take me to the funeral home, I guess.”
* Leo Tolstoy (Count Lev Nikolayevich Tolstoy; 9 Sep 1828 – 20 Nov 1910, was a Russian writer, best known for the novels War and Peace and Anna Karenina, is regarded as one of the greatest authors of all time.)
– “He spoke with such self-confidence that his hearers could not be sure whether what he had said was very witty or very stupid.” * O. Henry (William Sydney Porter; 11 Sep 1862 – 5 June 1910; was an American short story writer. O. Henry’s short stories are known for their wit, wordplay, warm characterization, and surprise endings.)
– “She plucked from my lapel the invisible strand of lint (the universal act of woman to proclaim ownership).”
Friday funnies: Q. What do you call a professional banjo player without a significant other?
A. Homeless.
– Aaron Burton, Healesiville, AL This week’s blonde joke: A blonde takes her car to a mechanic and says, “It’s running rough.” The mechanic takes it in and returns a few minutes later. The blonde says, “Well, what’s the problem?” The mechanic replies, “Easy to fix — just crap in the carburetor.” The blonde asks, “How often do I have to do that?”
– Duane Stevens, Signal Hill, CA * * * * * * * * * * * * * * * * * * * *
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13. 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 * EXPORT ADMINISTRATION REGULATIONS (EAR): 15 CFR Subtit. B, Ch. VII, Pts. 730-774 – Last Amendment: 7 Sep 2016: 81 FR 61595-61612: Russian Sanctions: Addition of Certain Entities to the Entity List – 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 – Latest effective change: 8 Sep 2016; 81 FR 62004-62008: 22 CFR Parts 120, 125, 126, and 130; Public Notice: 9672; RIN: 1400-AD70; International Traffic in Arms: Revisions to Definition of Export and Related Definitions
– The only available fully updated copy (latest edition 8 Sep 2016) of the ITAR with all amendments 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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