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DCAA Issues Guidance On Revised Travel Cost Rule

Client Alert | 1 min read | 04.12.10

In response to the recent revision to the travel cost rule at FAR 31.205-46(b) and (c), which now limits allowable airfare costs to the lowest airfare available to the contractor, DCAA issued guidance on March 22, 2010, that identifies the "lowest airfare available" as that available to the contractor through direct negotiation with airlines or travel agents. The guidance advises that contractors' policies and procedures should provide for (a) documented, advance planning of travel that considers nonrefundable airfares and lower airfares negotiated with airlines, travel service providers, and credit card companies and (b) obtaining quotations from competing airlines or travel service providers.

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Client Alert | 3 min read | 10.15.25

Developers Adapt Timelines and Strategies for Wind and Solar Projects Following Recent IRS Guidance and Expected IRS Enforcement Activity

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....