Author: Dave Townsend

Dave is a Partner in the firm's Government Solutions and Investigations Practice Group. Dave focuses on advising clients on international trade and transactions, including U.S. economic sanctions, export controls, customs law, and national-security related matters. He also represents clients in antidumping, countervailing duty, and safeguard proceedings as well as matters involving the World Trade Organization and U.S. free trade agreements.

Tariffs Roundup

My colleagues published an excellent eUpdate on a number of trade developments this week. It’s been a lot, with USTR coming out with a slate of new 301 Tariffs following its investigation into forced labor related policies and practices, opening a new 301 investigation on intellectual property protection in Vietnam, adjustments to 232 duties and more. Here is a link...

Massive New Section 301 Investigations Present Opportunity for Comment

In the wake of the Supreme Court’s February 20 decision striking down the authority of the United States Trade Representative to impose tariffs under IEEPA, USTR has been exploring other tariff authorities, including an immediate use of Section 122. It is now turning to its more traditional, investigative authorities, though to an unprecedented degree. On March 11, 2026 and then...

Are New Tariffs on Solid Legal Footing Under Section 122?

President Trump is imposing new tariffs effective on Tuesday, February 24, under Section 122 of the Trade Act of 1974 (“Section 122”). The Section 122 tariffs replace the tariffs imposed under the International Emergency Economic Powers Act (“IEEPA”), and that the Supreme Court on Friday found unlawful. Does a solid legal footing exist for the Section 122 tariffs? Given the...

Where things Stand After a Monumental Day on Tariffs

February 20, 2026 started off with arguably the most economically significant Supreme Court ruling in living memory when the Court struck down the White House’s use of IEEPA authority for tariffs representing roughly half of collected tariff revenue over the last year. The day ended with executive orders from an undeterred White House laying out a course for its continued...

Notebook Pages Up Close

USDA Updating its Foreign Investment in Ag Disclosure Process

Since the late 1970s, USDA has been collecting information regarding foreign ownership of agricultural lands under the Agricultural Foreign Investment Disclosure Act of 1978 (“AFIDA”). This little known, and often overlooked law, requires foreign persons to notify USDA of transactions that result in the foreign ownership or control of agricultural and forest lands within 90 days of securing the interest....