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The State of the Union, Suspension and Debarment Edition

Client Alert | less than 1 min read | 06.22.16

On June 15, 2016, the Interagency Suspension and Debarment Committee transmitted its annual report to Congress concerning the status of the federal suspension and debarment system, known as the “873 Report” after section 873 of Public Law 110-417, which requires the annual reporting. The 873 report evidences a slight decline in suspensions, proposed debarments, and debarments from FY 2014 to FY 2015, and an overall increase in the use of “alternatives to exclusion” such as administrative agreements (up 25 percent), and show cause letters (up 30 percent).

Insights

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....