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 | 10 min read | 10.23.25
The EU’s Defense Readiness Roadmap and Omnibus: What are the Implications for Defense Procurement?
On October 16, 2025, the European Commission and the High Representative of the Union for Foreign Affairs and Security Policy presented their Defense Readiness Roadmap 2030 to the EU Member States. This comprehensive plan aims to strengthen European defense capabilities. It follows, and should be read together with, the Commission’s Defense Readiness Omnibus that was published in June 2025. The Omnibus contains a set of proposals to facilitate defense investments and boost EU Member States’ responsiveness to today’s security challenges.
Client Alert | 5 min read | 10.22.25
Sixth Circuit Reaffirms Privilege Protections During Internal Investigations
Client Alert | 4 min read | 10.21.25
Pivot Point for 340B: HRSA Rebate Model Pilot Program Approaches Launch
Client Alert | 5 min read | 10.20.25
What’s new for Belgian Construction Contracts under the New Book 7 of the Civil Code
