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DoD Relaxes Cost Rules For Katrina Donated Leave

Client Alert | less than 1 min read | 10.14.05

Under a DoD policy memo issued October 11, 2005 (http://www.acq.osd.mil/dpap/policy/policyvault/2005-1399-DPAP.pdf), the costs of vacation and personal leave – but not sick leave – donated by contractor employees to charitable organizations providing assistance to victims of Hurricane Katrina will be treated as allowable compensation costs rather than unallowable donations. Consistent with parallel guidance from the IRS, the DoD policy applies to payments made to charitable organizations before January 1, 2007.

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Client Alert | 3 min read | 07.13.26

Amici Rally Behind Liberty Global, Urging Tenth Circuit to Rein in Economic Substance Doctrine

Following the 10th Circuit's April 21, 2026, decision affirming the disallowance of Liberty Global’s $2.4 billion deduction under the codified economic substance doctrine, I.R.C. § 7701(o), Liberty Global filed a petition for panel rehearing or rehearing en banc on June 5, 2026. That petition has since drawn significant amicus support from various industry groups representing large taxpayers, as discussed below....