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Proposed DFARS Rule to Provide Guidance on Assessing Commercial Price Reasonableness

Client Alert | less than 1 min read | 08.05.15

On August 3, the DoD issued a proposed rule, with comments due by October 2, to amend the DFARS to clarify the amount and types of data that contracting officers may require from contractors in order to perform price reasonableness assessments for commercial items. The proposed rule addresses (1) the conditions under which prior sales information is sufficient, (2) when "uncertified cost data" will be required and the required format, and (3) the limits on requiring additional cost information when there are "sufficient nongovernment sales to establish reasonableness of price."


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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....