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OMB and DoD Do Sequestration Two-Step

Client Alert | less than 1 min read | 08.13.12

On August 1, 2012, Acting OMB Director Jeffrey Zients and Deputy Secretary of Defense Ashton Carter testified before the House Armed Services Committee regarding the potential impacts of sequestration set to begin on January 2, but declined to spell out whether OMB would apply sequestration at the program, project, or activity level – the key to determining whether agencies would have some discretion to pick and choose among contracts. Sec. Carter hinted that DoD would follow that approach, stating that the DoD leadership "will take advantage of any flexibility [they] can find" to reach the target cuts, although any such flexibility is already restricted by the Administration's announcement that payroll accounts for military personnel would be exempt.

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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....