Defacto Debarment: Broad Contracting Prohibitions For Many Expatriate Corporations
Client Alert | 1 min read | 07.10.09
On July 1st , the FAR Council issued a broad-reaching prohibition on using fiscal year 2006-2009 appropriated funds for contracting with any corporation (or subsidiary of a corporation) that is an inverted domestic for the purposes of the Internal Revenue Code (26 USC 7874) or would be considered an inverted domestic under the Code except for the fact that the inversion transactions were completed on or before March 4, 2003. This new rule contains a much broader prohibition on federal contracting than any previous statute or regulation, applying the tax law definition of inverted domestic (and eliminating the 2003 grandfather provision), instead of the ;narrower definition contained in the Department of Homeland Security statute (6 USC 395).
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Client Alert | 4 min read | 04.09.26
DOJ Establishes National Fraud Enforcement Division
On April 7, 2026, Acting Attorney General Todd Blanche issued a memorandum establishing the National Fraud Enforcement Division (NFED) within the U.S. Department of Justice (DOJ). This new division will be dedicated to the centralized, coordinated investigation and prosecution of fraud against taxpayer dollars and taxpayer-funded programs. AAG Blanche acknowledged that, while DOJ has a “storied history of combatting fraud,” DOJ has “never adopted a comprehensive and coordinated approach to investigating and prosecuting fraud against taxpayer dollars and tax-payer funded programs.” The NFED was created to close that gap with its core mission being to “zealously investigate and prosecute those who steal or fraudulently misuse taxpayer dollars.”
Client Alert | 2 min read | 04.09.26
OMB Issues New Policy on Federal IT Transparency and Acquisition Oversight
Client Alert | 3 min read | 04.09.26
Preserve It or Lose It: A Missing Jury Instruction Costs Columbia University $94M in Damages
Client Alert | 5 min read | 04.09.26
U.S. State Privacy Enforcement: Key Priorities and Practical Guidance From State Regulators
