It’s Time for a Raise! DoD Proposes to Increase CPSR Threshold
Client Alert | 1 min read | 06.11.19
On May 31, 2019, DoD issued a proposed rule, which would amend the Defense Acquisition Regulation Supplement (DFARS) to establish a DoD-specific Contractor Purchasing System Review (CPSR) threshold of $50M at DFARS 244.302, to be used in lieu of $25M threshold at FAR 44.302(a), which has remained unchanged since 1996. According to the Federal Register, it is estimated that, with this new threshold in place, DCMA ACOs can reduce the number of contractor reviews by approximately 20% (from around 667 to 534), which would reduce the burden on smaller contractors and allow a more efficient and effective use of CPSR resources to review larger contractors where more taxpayer dollars are at risk. Comments on the rule are due by July 30, 2019.
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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.
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Department of War Immediately Suspends CMMC Phase II Requirements, Launches 60-Day Reform Review
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Client Alert | 5 min read | 07.10.26

