Case No. IA-16030

Date issued: Aug. 30 2011

Last substantive commentary amendment:
Jan. 02 2024

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TURBOFAC Commentary (1190 words)

Notes:

1) BACKGROUND

This guidance letter interprets a provision in the old ITR (560.505(a)) that, in substance, now appears at section 560.554 of the ITSR. For the ITR as they appeared at the time, see https://www.govinfo.gov/content/pkg/CFR-2011-title31-vol3/xml/CFR-2011-title31-vol3-part560.xml.

Section 560.505(a) (2011) of the ITR provided as follows:

“The importation of Iranian-origin services into the United States or other dealing in such services is authorized where such services are performed in the United States by an Iranian citizen or national for the purpose of, or which directly relate to, participating in a public conference, performance, exhibition or similar event, and such services are consistent with that purpose.”

Here, OFAC interprets 560.505(a) such that it...