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Crackdown On Contractors With Tax Delinquencies

Client Alert | less than 1 min read | 01.27.10

On January 20, 2010, President Obama issued a memorandum directing OMB to evaluate practices of contracting officers and debarring officials in response to contractors' certifications regarding serious tax delinquencies and to provide him, within 90 days, recommendations to ensure that contractors with any such delinquencies are not awarded new federal contracts. Additionally, the President directed the Commissioner of Internal Revenue to conduct a review of the accuracy of contractors' certifications of non-delinquency that companies bidding for federal contracts must submit.

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Client Alert | 3 min read | 05.28.26

PFAS Regulatory Alert: EPA Rolls Back RCRA Proposed Rule on “Hazardous Waste” but Does Not Disturb Proposed RCRA Rule on PFAS

Earlier this month, the U.S. Environmental Protection Agency (EPA) withdrew a February 2024 Biden administration proposed rule, “Definition of Hazardous Waste Applicable to Corrective Action for Releases From Solid Waste Management Units,” under the Resource Conservation and Recovery Act (RCRA).[1] The withdrawn proposal would have revised RCRA corrective action regulations to expressly apply the broader statutory definition of “hazardous waste,” rather than only the narrower regulatory definition. Now, EPA is maintaining the status quo for corrective action under RCRA. However, EPA’s withdrawal of its proposed RCRA hazardous waste definition makes no mention of its corresponding proposal from 2024 to list nine per- and polyfluoroalkyl substances (PFAS) as RCRA hazardous constituents.[2] This disjointed withdrawal, while providing some certainty for regulated entities, does not resolve how EPA plans to address PFAS under the RCRA program....

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