1. Home
  2. |Insights
  3. |DoD Rescinds IR&D "Technical Interchange" Requirement

DoD Rescinds IR&D "Technical Interchange" Requirement

Client Alert | 1 min read | 09.04.18

On August 24, 2018, the Department of Defense (DoD), issued a final rule that, effective immediately, removes the requirement in Defense Federal Acquisition Regulation Supplement (DFARS) 231.205–18(c)(iii)(C)(4) that major contractors conduct a formal discussion (i.e., “technical interchange”) with a DoD technical staffer prior to generating independent research and development (IR&D) costs for IR&D projects initiated in fiscal year 2017 and later, in order for those costs to be allowable. The requirement applied to major contractors, who are defined as contractors whose covered segments allocated a total of more than $11 million in IR&D and bid proposal costs to covered contracts during the preceding fiscal years. The requirement was repealed after a determination by the DoD Regulatory Reform Task Force that the DFARS requirement was unnecessary since the objective of the interchange “can be met through other means.”


Contacts

Insights

Client Alert | 11 min read | 12.15.25

New York LLC Transparency Act: Key Requirements and Deadlines

On January 1, 2026 (“Effective Date”), the New York LLC Transparency Act ("New York Act”) is scheduled to take effect, introducing new disclosure requirements for limited liability companies (“LLCs”) formed or registered to do business in New York State.  The New York Act is expected to impose the type of broad beneficial ownership requirements the federal CTA and rules implementing it was designed to require, before the federal government’s decision to limit the scope of the CTA’s beneficial ownership reporting requirements to foreign companies and foreign beneficial owners....