Compound Interest On CAS

In Raytheon Co. (Aug. 22, 2007), the ASBCA held that segment closing adjustments under CAS 413 should be treated as "CAS noncompliances," making interest due on the adjustment from the date of the segment closing, and that the interest calculation is to be compounded daily because the Internal Revenue Code (IRC) requires that the IRS interest rate applicable by cross-reference from the CAS statute be compounded daily. It does not appear that the contractor argued -- and the Board therefore did not address -- that the CAS statute incorporates into CAS only the section of the IRC containing the interest rate, 28 U.S.C. 6621, not the section of the IRC requiring compounding daily, 28 U.S.C. 6622, or that the interest rate due for contracts awarded before the cross-reference to the IRC was added to the CAS statute should be subject to the prior rates that applied to those contracts.