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TAA Thresholds: Downward Trend Continues for 2018-2019

Client Alert | less than 1 min read | 12.13.17

On December 11, 2017, the U.S. Trade Representative published its biennial readjustment of U.S. dollar thresholds for government procurements covered by the Trade Agreements Act. The new thresholds, which go into effect January 1, 2018 for calendar years 2018 and 2019, reflect a continued decline in threshold values since the 2014-2015 revision, coinciding with the stronger value of the U.S. dollar relative to the other currencies included in market basket of currencies constituting the IMF’s Special Drawing Rights (SDRs) used to establish the thresholds contained in the WTO’s Agreement on Government Procurement.

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Client Alert | 1 min read | 04.18.24

GSA Clarifies Permissibility of Upfront Payments for Software-as-a-Service Offerings

On March 15, 2024, the General Services Administration (GSA) issued Acquisition Letter MV-2024-01 providing guidance to GSA contracting officers on the use of upfront payments for acquisitions of cloud-based Software-as-a-Service (SaaS).  Specifically, this acquisition letter clarifies that despite statutory prohibitions against the use of “advance” payments outside of narrowly-prescribed circumstances, upfront payments for SaaS licenses do not constitute an “advance” payment subject to these restrictions when made under the following conditions:...