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Offerors Beware: Exceptions to Data Rights Requirements May Prove Fatal

Client Alert | less than 1 min read | 02.03.16

In Deloitte Consulting, LLP (released Jan. 14, 2016), GAO held that, because the awardee’s proposal had taken exception to a solicitation provision that granted the government broader rights in materials (including software source code) than the rights conveyed by the FAR's standard data rights clause, it was unacceptable. This case serves as a reminder that the time for objecting to solicitation provisions, including those relating to technical data and computer software rights, is prior to proposal submission.

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Client Alert | 3 min read | 07.13.26

Amici Rally Behind Liberty Global, Urging Tenth Circuit to Rein in Economic Substance Doctrine

Following the 10th Circuit's April 21, 2026, decision affirming the disallowance of Liberty Global’s $2.4 billion deduction under the codified economic substance doctrine, I.R.C. § 7701(o), Liberty Global filed a petition for panel rehearing or rehearing en banc on June 5, 2026. That petition has since drawn significant amicus support from various industry groups representing large taxpayers, as discussed below....