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Japan (and Slovenia) Become "Qualifying Countries"

Client Alert | less than 1 min read | 08.05.16

To implement recently executed reciprocal defense procurement agreements with Japan and Slovenia, DoD on August 2 issued a final rule adding both countries to the list of 23 other “qualifying countries.” This designation will open DoD procurements to products from these countries, allow U.S. defense contractors to incorporate manufactured components from those countries into their end products as if they were U.S. manufactured components, and obviate specialty metal restrictions regarding those countries and their end products and components.

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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....