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Federal Circuit Compounds Contractors' Interest Problems

Client Alert | 1 min read | 03.04.11

Over the vigorous dissent by several judges, the Federal Circuit on March 1, 2011, denied a petition for en banc review of its decision 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 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. As we reported on September 24, 2010, the same interest rate is referenced in the Truth in Negotiations Act (TINA), and a proposal is pending to amend the FAR to require compound, rather than simple, interest to be used in calculating damages for TINA violations.

Insights

Client Alert | 6 min read | 11.03.25

ICE Is Suddenly At The Door: How Retailers, Hospitals, And Hotels Can Survive The Surprise Visitor

Imagine a typical morning at your retail store, hospital, or hotel—customers are arriving, staff are busy, and suddenly, federal agents from ICE appear at your front desk. The surprise is real, but panic does not have to be. Unannounced inspections conducted by Immigration and Customs Enforcement (ICE) inspectors have been occurring for years, but in recent months, ICE has ramped up inspection visits across the service sector, targeting I-9 compliance and employment records. These visits are not always dramatic raids; more often, they are routine checks that can escalate if your team is not prepared....