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DOL Again Applies Expansive Interpretation of "Subcontractor"

Client Alert | less than 1 min read | 10.29.10

In Office of Fed. Contract Compliance Programs v. Fla. Hosp. of Orlando (Oct. 28, 2010), a DOL Administrative Law Judge determined that a hospital providing medical services pursuant to an agreement with a TRICARE-managed care support contractor was a government subcontractor for purposes of a DOL audit of the hospital's compliance with its affirmative action and non-discrimination obligations. As discussed further in our blog, the ALJ analogized the hospital's status in this case to the hospital that provided medical services pursuant to an agreement with an FEHBP contractor in the UPMC Braddock case last year, which is currently under appeal.

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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....