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White House and Military Departments Release Guidance as (Another) Budget Deadline Approaches

Client Alert | 1 min read | 01.18.13

In the past week, OMB, DoD, Army, Air Force, and Navy have all released guidance directing their subordinate entities to begin planning for the possibility of sequestration (presently scheduled to result in the cancellation of approximately $85 billion in FY13 budgetary resources) beginning on March 1, 2013, and for the expiration of the FY13 Continuing Appropriations Resolution (which expires on March 27, 2013, and must either be extended or replaced with new appropriations acts to prevent a lapse in appropriations and government shutdown). While the guidance cautions that efforts to prevent sequestration and ensure continued appropriations are underway, the memos acknowledge that, as a practical matter, agencies must begin planning for the possibility that they will need to operate with dramatically reduced budgetary resources.


Insights

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....