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Prior COVID-19 Travel Bans Repealed as of November 8, 2021

On October 25, 2021, President Biden announced the suspension of the COVID-19 travel bans from Brazil, China, India, Iran, Ireland, the Schengen Area, South Africa, and the United Kingdom.  Previously, a National Interest Exception waiver was required.  With this new Proclamation, the White House announced a global vaccination requirement for all adult foreign national air travelers and authorized the Centers for Disease Control (CDC) to provide specific regulations.  The White House announcement can be found here.Continue Reading Sheppard Mullin Travel Checklist ‒ New Vaccination Travel Restrictions for Entry Into the United States: Air and Land Rules Effective November 8, 2021

On July 6, 2021 the U.S. State Department publicly announced that the travel ban waivers related to the world-wide pandemic will now be good for 1 year and multiple entry.  The effective date of this new decision is June 29, 2021.  Previously they were only good for 30 days and a single entry.  In addition, those that have received a waiver in the past may now use it for 12 months if it was granted after June 29, 2020.  See: https://travel.state.gov/content/travel/en/News/visas-news/extension-validity-for-nies-for-china-iran-brazil-south-africa-schengen-uk-ireland-india.html
Continue Reading NIE’s Now Good for 1 Year, More on Navigating the Travel Ban Jungle: National Interest Exception Checklist for the U.S. COVID Travel Bans

On January 6, 2020, the SBA published its 26th Interim Final Rule (the First Draw PPP IFR) and 27th Interim Final Rule (the Second Draw PPP IFR)[1] with respect to the Paycheck Protection Program (PPP), as reauthorized and modified under Title III (cited as the Economic Aid to Hard-Hit Small Businesses, Nonprofits, and Venues Act (the Economic Aid Act)) of Division N of the Consolidated Appropriations Act, 2021.  The PPP was originally enacted under the Coronavirus Aid, Relief, and Economic Security Act (as amended, supplemented or otherwise modified from time to time prior to the enactment of the Economic Aid Act, including by the Paycheck Protection Program and Health Care Enhancement Act, the Paycheck Protection Program Flexibility Act, applicable federal regulations and interpretive guidance issued by the SBA and Treasury, the CARES Act).
Continue Reading Paycheck Protection Program: SBA Issues Guidance on First Draw and Second Draw PPP Loans and Releases PPP Applications Pursuant to the Economic Aid Act

Relief on Substantial Presence and Treaty Day-Count Tests.

On May 30th, the IRS issued Revenue Procedure 2020-20 which provides non-U.S. individuals present in the U.S. some limited relief from the day-count tests for U.S. tax residency and for eligibility for certain treaty benefits.  The relief comes in the form of the “COVID-19 Medical Condition Travel Exception”.  The name of the exception is a misnomer because individuals need not have had any medical condition (including the COVID-19 virus) to claim its benefits.
Continue Reading IRS Provides Some Relief to Offset COVID-19 Related Travel Restrictions

The U.S. Congress has passed a series of laws for easing the economic suffering due to COVID-19, including the Coronavirus Aid, Relief, and Economic Security Act, or CARES Act.  The CARES Act and other relief bills have appropriated about $3 trillion for assistance to companies.  As companies receive these funds, attention is now turning to the oversight and enforcement that is already beginning and will vastly increase over the coming months.
Continue Reading U.S. Government Assistance in Response to COVID-19: Investigations Are Coming

The US Federal Reserve has confirmed in its Main Street Loans frequently-asked-questions-faqs about the Main Street lending program (the “FAQ”) that US subsidiaries of foreign companies can be eligible borrowers under the various loans available under the program so long as they otherwise meet the other conditions to eligibility for the loans.
Continue Reading Main Street Loan Program – US Subsidiaries of Foreign Companies Can Apply

New York Partner Valérie Demont and Associate Karl Buhler authored an article about the CARES Act and its benefits and pitfalls for French companies doing business in the United States, which was published in the French leading legal review “Les Editions Legislatives.”
Continue Reading The U.S. economic recovery plan: benefits, limits and risks for French companies in the United States