Compounding The Problem
Client Alert | 1 min read | 09.24.10
On September 22, 2010, the Civilian Agency Acquisition Council and Defense Acquisition Regulations Council issued a proposed rule that would amend the FAR to require compound, rather than simple, interest to be used in calculating damages for violations of the Truth in Negotiations Act (TINA). The proposal follows the problematic analysis in Gates v. Raytheon, 584 F.3d 1062 (Fed. Cir. 2009), which held that, because the Cost Accounting Standards (CAS) statute requires interest on cost impacts for CAS violations to be calculated at the rate established under 26 U.S.C. § 6621, the same rate referenced in the TINA statute, the interest must be compounded in accordance with 26 U.S.C. § 6622, even though the CAS statute does not refer to or incorporate § 6622 by reference.
Insights
Client Alert | 2 min read | 02.23.26
NYC’s Mayor Mamdani Joins the Wave of Local Consumer Protection Enforcement
While state attorneys general have traditionally led consumer protection enforcement, local governments are increasingly deploying their own powers to prosecute high-stakes affirmative litigation. The results speak for themselves: Los Angeles and Chicago have secured multi-million-dollar judgments and settlements in consumer deception cases over the past decade.
Client Alert | 1 min read | 02.23.26
SCOTUS Tariff Decision: Implications for Retail and E-Commerce
Client Alert | 5 min read | 02.23.26
UK Government Seeks Evidence on Ownership and Control in Financial Sanctions Regulations
Client Alert | 4 min read | 02.20.26
