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Risk Of Accepting Out-Of-Scope Task/Delivery Orders Gets Greater

Client Alert | less than 1 min read | 10.07.04

Adding to the risk of accepting out-of-scope work that potentially could result in avoidance of the contract order, the GSA debarring official has recently put the burden on the contractor to police the situation: "We cannot have a situation where a contractor knows or should have known that something is wrong and does not at least raise the issue with the contracting officer, or, if appropriate, higher authority. On a case-by-case basis, if we determine that a contractor has not followed the rules, we may take appropriate action in the context of contractor responsibility."

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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....