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Tough (Tax) Break: Federal Tax Delinquency and Felony Convictions Could Bar Corporations from Awards

Client Alert | 1 min read | 10.05.16

The FAR Council published a final rule on September 30 that, effective immediately, adopts an interim rule that requires any corporation responding to a federal solicitation to represent whether it has (1) any unpaid federal tax liability that has been assessed and is not being appealed or paid in a timely manner or (2) a felony conviction under any federal law within the preceding 24 months. As further explained here, any affirmative disclosure would create an automatic bar against contract award, unless the agency’s suspension and debarment official has considered the matter and determined that further action is not necessary to protect the government’s interests.

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Client Alert | 7 min read | 12.17.25

CARB Proposes Regulations Implementing California GHG Emissions and Climate-Related Financial Risk Reporting Laws

After hosting a series of workshops and issuing multiple rounds of materials, including enforcement notices, checklists, templates, and other guidance, the California Air Resources Board (CARB) has proposed regulations to implement the Climate Corporate Data Accountability Act (SB 253) and the Climate-Related Financial Risk Act (SB 261) (both as amended by SB 219), which require large U.S.-based businesses operating in California to disclose greenhouse gas (GHG) emissions and climate-related risks. CARB also published a Notice of Public Hearing and an Initial Statement of Reasons along with the proposed regulations. While CARB’s final rules were statutorily required to be promulgated by July 1, 2025, these are still just proposals. CARB’s proposed rules largely track earlier guidance regarding how CARB intends to define compliance obligations, exemptions, and key deadlines, and establish fee programs to fund regulatory operations....