Client Alerts 

A Guide to the New Tariff Duty Refund Process
by Karl W. Means on April 21, 2026
Following the U.S. Supreme Court’s ruling striking down most of the tariffs imposed by President Donald Trump under International Emergency Economic Powers Act of 1977 (IEEPA), and the Court of International Trade declaration that "every single cent of IEEPA duties that were imposed must be returned,” the question for U.S. Customs and Border Protection (CBP) — and importers — has been how to refund more than $166 billion in IEEPA tariffs collected over 53 million entries filed by over 330,000
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What Importers Should Know Now in the Wake of the Supreme Court’s Tariffs Decision
by Karl W. Means on February 23, 2026
The U.S. Supreme Court on Friday struck down most of the tariffs imposed by President Donald Trump under the International Emergency Economic Powers Act of 1977 (IEEPA). But questions remain for importers and others affected by the IEEPA tariffs: How and when will importers receive refunds of IEEPA duties already paid? What will be the impact of the new tariffs announced Friday by the Trump administration? What is the status of the trade agreements negotiated with certain trading partners in response to the
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How Importers Can Be Proactive Awaiting the Supreme Court’s Tariff Decision
by Karl W. Means on February 16, 2026
Between now and when its term ends in June, the United States Supreme Court is expected to decide whether global “reciprocal” tariffs imposed by President Donald Trump under the International Emergency Economic Powers Act of 1977 (IEEPA) are unlawful. The much-anticipated decision could come at any time and, no matter the outcome, likely will significantly change the U.S. tariff landscape in both the short- and long-term. Here’s what importers need to know as they wait. How We Got Here The question before
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Commerce Department Expands End-User Restrictions with New ‘Affiliates Rule’
by Kathryn J. Carlson, Mitchell D. Dolman on October 16, 2025
The Department of Commerce’s Bureau of Industry and Security (BIS) has issued an interim final rule (IFR) that extends end-user restrictions to entities owned 50% or more by parties identified on the Entity List and the Military End-User (MEU) List. This new “Affiliates Rule” substantially expands the reach of Entity List and MEU List restrictions by prohibiting unlicensed exports to a large number of new unlisted companies based on their ownership chains, particularly the subsidiaries of listed Chinese entities. It further
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U.S. Continues to Ease and Clarify Restrictions on Syria
by Kathryn J. Carlson on October 02, 2025
The U.S. Departments of Commerce and the Treasury took steps this September to further ease restrictions on Syria following the fall of the Assad regime. In early September, the Commerce Department’s Bureau of Industry and Security (BIS) revised the Export Administration Regulations (EAR) to relax certain export controls on Syria. On September 25, the Treasury Department’s Office of Foreign Assets Control (OFAC) renamed the “Syria-Related Sanctions Regulations” the “Promoting Accountability for Assad and Regional Stabilization Sanctions Regulations,” further clarifying the
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A Golden Share and an Order to Unwind: Early Lessons in CFIUS from the New Administration
by Kathryn J. Carlson on July 25, 2025
On July 8, 2025, President Trump issued an order to unwind the acquisition of Jupiter Systems, Inc., a U.S. company, by Hong Kong-based Suirui International Co., Ltd., a subsidiary of China’s Suirui Group (collectively Suirui), five years after the transaction closed. According to the Treasury Department’s July 11 statement, the Committee on Foreign Investment in the United States (CFIUS) had “identified a national security risk arising from Suirui’s ownership of Jupiter relating to the potential compromise of Jupiter’s products used
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Federal Trade Court Strikes Down Bulk of Trump Tariffs
by Karl W. Means, Russell V. Randle on May 29, 2025
A three-judge panel of the United States Court of International Trade late Wednesday afternoon struck down the reciprocal tariffs imposed last month by the Trump administration. The court, in a per curiam decision, held that the powers delegated to the President under the International Emergency Economic Powers Act of 1977 (IEEPA) do not confer the “unbounded authority” to “impose unlimited tariffs on goods from nearly every country in the world.” V.O.S. Selections, Inc., et al. v. United States, No. 25-00066
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U.S. Provides Significant Sanctions Relief for Syria
by Kathryn J. Carlson on May 29, 2025
Less than two weeks after President Donald Trump announced that his administration would lift U.S. sanctions on Syria, the U.S. Departments of the Treasury and State took significant first steps to provide the anticipated sanctions relief. On May 23, the Treasury Department’s Office of Foreign Assets Control (OFAC) issued General License 25 (GL 25), authorizing a broad range of transactions that had previously been prohibited under the Syrian Sanctions Regulations. In parallel, the State Department exercised its authority under the Caesar
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Lifting Sanctions On Syria: A Preview of the Process
May 15, 2025
President Donald Trump announced Tuesday during his trip to the Middle East that his administration would lift U.S. sanctions on Syria. Since the shock collapse of Bashar al-Assad’s regime in Syria late last year, the United States and broader international community have debated whether sanctions on Syria should be removed. After years of comprehensive restrictions, Syria’s people and economy could benefit dramatically from sanctions relief. If the administration follows through with Trump’s announcement, U.S. and international exporters, financial institutions and other
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Left Out of ‘Liberation Day’: Demystifying Continuing Import Sanctions and Tariffs on Russia
by Karl W. Means, Russell V. Randle on April 25, 2025
President Donald Trump issued an executive order (EO) earlier this month announcing sweeping “reciprocal” tariffs on imports from countries across the world. One country missing from the EO’s increased tariffs was Russia, despite its ongoing trade surplus with the United States. In response to the scrutiny this has drawn, the White House offered existing U.S. sanctions on Russia as the basis for its exclusion. While the EO’s more substantial “reciprocal” tariffs are currently suspended (except for China), these discussions raise the
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Review of the Current Sanctions and Export Controls on Russia as Military Advances through Ukraine
by Russell V. Randle, Karl W. Means on March 03, 2022
Ukraine flag on a flagpole.
Highlights This Miles & Stockbridge alert provides a summary of the latest sanctions and developments regarding the ongoing situation in Ukraine. In response to Russia’s continued war operations and military attacks throughout Ukraine, the U.S. government and its allies imposed many more sanctions and new export control restrictions in the past week, specifically targeting Russian financial institutions, Russian state-owned enterprises, Russian elites,  and several of Russia's critical industrial sectors. In response to the Russian invasion and continued war operations throughout Ukraine, the U.S.
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Final Rule Adds Sweeping Restrictions on Exports to Russia in Response to Further Invasion of Ukraine
by Russell V. Randle, Karl W. Means on February 25, 2022
Yesterday (February 24th) as part of the broader response to Russia’s invasion of Ukraine – the White House announced strict export controls as part of the Biden Administration’s strategy to “squeeze Russia’s access to finance and technology for strategic sectors of its economy for years to come.” (President Biden’s remarks are found here.)  Those controls are part of a Final Rule “Implementation of Sanctions Against Russia Under the Export Administration Regulations (EAR)” (unpublished PDF version is found here) which, although
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