New IRS Requirements for EIN Applications Go Into Effect May 13, 2019

April 16, 2019
As we have all been scrambling to get our taxes completed this month, a new IRS requirement may have been overlooked that goes into effect on May 13, 2019.

SBA Seeks Comments on Reducing Unnecessary Regulatory Burden

August 15, 2017
On August 15, 2017, the U.S. Small Business Administration ("SBA") released a request for information ("RFI") seeking input from the public as to which SBA regulations should be repealed, replaced, or modified because they are obsolete, unnecessary, ineffective, or burdensome.

Client Alert - Overview of Select Provisions on the SBA's Final Rule of Limitations on Subcontracting

June 10, 2016
On May 31, 2016, SBA released its long anticipated final rule on the limitations on subcontracting. The final rule becomes...

Comments on Proposed Rule Regarding Small Business Subcontracting Improvements

August 7, 2015
After the recent small business subcontracting plan changes were implemented by the U.S. Small Business Administration (“SBA”) in its final rule at 78 Fed. Reg. 42391, dated July 16, 2013, many of our clients have asked us how the SBA’s new rules should be interpreted in light of the existing FAR small business subcontracting requirements. We believe that the FAR Councils are taking the right steps to harmonize the SBA’s requirements with the obligations the FAR imposes. However, we believe that there are several aspects of the proposed rule that could be amended to provide greater clarity and less burdensome outcomes for contractors administering subcontracting plans, particularly contractors that maintain commercial plans.

Analysis of the Fair Pay and Safe Workplaces Proposed Rule

July 2, 2015
On May 28, 2015, the Defense Department, General Services Administration and National Aeronautics and Space Administration announced the Federal Acquisition Regulatory Council’s proposed rule to implement Executive Order 13673 “Fair Pay and Safe Workplaces” (EO), dated July 31, 2014. Together with the proposed Federal Acquisition Regulation (FAR), the Department of Labor (DOL) published proposed guidance (collectively, “Proposed Rules”), defining many terms set forth in the EO and beginning to establish a framework of expectations. PilieroMazza addressed the requirements of the EO and identified prospective concerns in its Legal Advisor article "The Impact of the Fair Pay and Safe Workplaces Executive Order on Contract Procurement." While some of questions about the EO and its implementation have been answered in the Proposed FAR and DOL regulations, many of the concerns still remain. The deadline to submit comments has been extended to August 11, 2015.
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