Federal Circuit Compounds Contractors' Interest Problems
Client Alert | 1 min read | 03.04.11
Over the vigorous dissent by several judges, the Federal Circuit on March 1, 2011, denied a petition for en banc review of its decision in Gates v. Raytheon, 584 F.3d 1062 (Fed. Cir. 2009), which held that, because the Cost Accounting Standards (CAS) statute requires interest on cost impacts for CAS violations to be calculated at the rate established under 26 U.S.C. § 6621, the interest must be compounded in accordance with 26 U.S.C. § 6622, even though the CAS statute does not refer to or incorporate § 6622 by reference. As we reported on September 24, 2010, the same interest rate is referenced in the Truth in Negotiations Act (TINA), and a proposal is pending to amend the FAR to require compound, rather than simple, interest to be used in calculating damages for TINA violations.
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Client Alert | 7 min read | 12.17.25
After hosting a series of workshops and issuing multiple rounds of materials, including enforcement notices, checklists, templates, and other guidance, the California Air Resources Board (CARB) has proposed regulations to implement the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261) (both as amended by SB 219), which require large U.S.-based businesses operating in California to disclose greenhouse gas (GHG) emissions and climate-related risks. CARB also published a Notice of Public Hearing and an Initial Statement of Reasons along with the proposed regulations. While CARB’s final rules were statutorily required to be promulgated by July 1, 2025, these are still just proposals. CARB’s proposed rules largely track earlier guidance regarding how CARB intends to define compliance obligations, exemptions, and key deadlines, and establish fee programs to fund regulatory operations.
Client Alert | 1 min read | 12.17.25
Client Alert | 7 min read | 12.17.25
Executive Order Tries to Thwart “Onerous” AI State Regulation, Calls for National Framework
Client Alert | 4 min read | 12.17.25
The new EU Bioeconomy Strategy: a regulatory framework in transition
