Client Alerts & Newsletters

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

October 5, 2016

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.

For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.

Lorraine M. Campos
Partner – Washington, D.C.
Phone: +1.202.624.2786

M. Yuan Zhou
Counsel – Washington, D.C.
Phone: +1.202.624.2666

Crowell & Moring LLP is an international law firm with offices in the United States, Europe, MENA, and Asia that represents clients in litigation and arbitration, regulatory and policy, and transactional and corporate matters. The firm is internationally recognized for its representation of Fortune 500 companies in high-stakes litigation and government-facing matters, as well as its ongoing commitment to pro bono service and diversity, equity, and inclusion.

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