Blanket Purchase Order Does Not Equal Task Order Contract
Client Alert | less than 1 min read | 01.19.10
In C & B Constr., Inc. (Jan. 6, 2010), GAO explained that it had jurisdiction to review protests of task orders issued under Blanket Purchase Agreements ("BPA"), even if the task order is valued less than $10 million (the statutory limit for GAO to review protests of task or delivery order contracts), because BPAs are different from task or delivery order contracts. GAO then sustained the protest because the source selection decision was based on numerical scores without adequate substantive discussion.
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On August 15, 2025, the Treasury Department and IRS released updated guidance concerning Beginning of Construction requirements to qualify for clean energy tax credits. This new guidance is critical for developers to consider as they rush to qualify for the tax credits before they expire entirely. The much-anticipated guidance followed the July 7, 2025 Executive Order 14315, Ending Market Distorting Subsidies for Unreliable, Foreign-Controlled Energy Sources (“July 7, 2025 Executive Order”), which signaled that the Trump Administration was planning to strictly enforce the termination of production and investment tax credits for solar and wind facilities that are set to expire under the One Big Beautiful Bill Act (OBBB Act), covered in more detail here. The new guidance comes at a time when many in the industry are struggling to keep up with the myriad ways that the new administration is working to roll back wind and solar tax credits, leaving developers to piece through the recent guidance to determine how best to structure and invest in clean energy projects given the volatile position of the current administration vis-a-vis wind and solar energy.
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Building Blocks of Design Law: CJEU rules on LEGO Group Modular Design Protection
