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Has the Bureau of Economic Analysis Contacted You About the BE-11 Survey?

Client Alert | less than 1 min read | 05.06.16

The Department of Commerce’s Bureau of Economic Analysis (BEA) is conducting the 2015 Annual Survey of U.S. Direct Investment Abroad (BE-11), which applies to U.S. entities that, during or at the end of fiscal year 2015, held at least 10% or more direct or indirect voting interest in a foreign business enterprise, and that meet certain other conditions identified in the Form BE-11. Completed surveys (or exemption forms) are due May 31, 2016, and while mandatory only for those contacted by BEA, it appears that many private equity funds ensnared by the 2014 Benchmark survey conducted last year have been contacted.

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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:...