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Crackdown On Contractors With Tax Delinquencies

Client Alert | less than 1 min read | 01.27.10

On January 20, 2010, President Obama issued a memorandum directing OMB to evaluate practices of contracting officers and debarring officials in response to contractors' certifications regarding serious tax delinquencies and to provide him, within 90 days, recommendations to ensure that contractors with any such delinquencies are not awarded new federal contracts. Additionally, the President directed the Commissioner of Internal Revenue to conduct a review of the accuracy of contractors' certifications of non-delinquency that companies bidding for federal contracts must submit.

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Client Alert | 8 min read | 10.01.25

BIS Issues “Affiliates Rule” to Dramatically Expand Applicability of Entity and Military End-User Lists

On September 29, 2025, the U.S. Department of Commerce Bureau of Industry and Security (BIS) announced a sweeping Interim Final Rule (IFR), (the “Affiliates Rule”) expanding which entities qualify as Entity List or Military End-User entities, thereby subjecting those entities to elevated export control restrictions under the Export Administration Regulations (EAR). U.S. export restrictions applicable to entities on the Entity List, Military End-User (MEU) List, and Specially Designated Nationals and Blocked Persons (SDN List) now apply to foreign affiliates that are, in the aggregate, owned 50% or more by one or more of the aforementioned entities. An entity that becomes subject to these restrictions because of its ownership structure will be subject to the most restrictive controls that attach to any of its parent entities, regardless of ownership stakes....