Section 3610 Billing Guidance
Client Alert | less than 1 min read | 04.13.20
Crowell & Moring has collected and analyzed the available, agency-specific billing guidelines for government contractors submitting CARES Act Section 3610 invoices. The information is collected here. A PDF version can be found here.
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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:
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Making the EU Courts More Efficient for Trade-Related Decisions
