‘Tis the Season: Contracting Officer’s Final Decisions on 2011 Incurred Costs
Client Alert | 1 min read | 07.02.18
For contractors that use a fiscal year that ends on 12/31 and submitted their 2011 incurred cost submissions to the Government in June of 2012, the 6-year deadline for the Government to assert a claim disallowing a portion of those costs is upon us. As a practical matter, DCAA’s well-documented audit backlog means that some COs are likely to receive audit reports only weeks before the deadline (or not at all), and may be inclined to issue COFDs disallowing all of the costs identified in DCAA’s audit reports, in order to preserve the Government’s right to pursue a claim. Contractors should be mindful of the 90-day limit to appeal a Final Decision even where they expect to negotiate a resolution with the Government.
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Client Alert | 4 min read | 09.10.26
European Commission Publishes Landmark Guidelines on Exclusionary Abuses by Dominant Companies
On 3 September 2026, the European Commission adopted new Guidelines on the application of Article 102 TFEU to abusive exclusionary conduct by dominant undertakings. The Guidelines follow a public consultation on a draft published in August 2024 and reflect substantial stakeholder feedback. They replace the Commission's 2008 Guidance on enforcement priorities (which ceases to apply 30 days after publication of the new guidelines in the Official Journal) and represent the most significant reset of the Commission's Article 102 enforcement framework in nearly two decades. The Commission's stated aim is to set out principles and operational guidance, enhance legal certainty, and help companies self-assess their exclusionary-abuse risk.
Client Alert | 5 min read | 09.09.26
Client Alert | 8 min read | 09.08.26
Saxon Woods Investments Limited v Costa [2026] UKSC 21: Good Faith in the Boardroom
Client Alert | 2 min read | 09.08.26
IRS Takes Aim: Proposed Rule Threatens Tax-Exempt Status of Private Schools
