Generally, to be eligible for the domestic production activities deduction (DPAD), a taxpayer must earn gross receipts from a disposition of qualifying production property. This typically involves a sale and delivery of a manufactured product by the taxpayer to a customer. However, the IRS recently ruled that a government contractor made a disposition for DPAD purposes despite the fact that title to the property reverted back to the contractor (Technical Advice Memorandum 201314043, 04/05/2013). The ruling disposition was not requiring
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As a follow-up to the L2 Federal Resources webinar on “Attributes of an Adequate Accounting System,” Aronson LLC government contracting specialists Nicole Mitchell and Brian Bender have prepared answers to several attendee questions:
Is my contract covered by the Cost Accounting Standards (CAS), and how do I determine the level of CAS coverage (e.g., Full, Modified, Not CAS Covered)?
Click here to download a flowchart that illustrates the method for determining CAS coverage and whether or not your company should be submitting a Disclosure Statement.
Does my company have a robust set of policies and procedures?
At a minimum, your business should have the following written policies and procedures (P&P) in place prior to DCAA review/audit: Continue reading »
The Federal Acquisition Institute courses and modules available on the Defense Acquisition University’s website provide online anytime training to assist with your understanding of GSA Schedules and offer continuous learning points (CLPs) that may count towards your contracting certification and continuing education.
You’ll learn how to effectively use the GSA Schedules program to meet your requirements, use GSA tools to enhance competition, achieve small business utilization, procure sustainable acquisitions and much more. Most courses require passing a test with a 100% score to earn CLP credits.
GSA Schedules related courses include: Continue reading »
GSA’s Multiple Award Schedules (MAS) webinar for November 2012 is on FAR Subpart 8.4 (Federal Supply Schedules) vs FAR Part 13 and FAR Part 15 (Open Market / Contracting by Negotiation). GSA offers a mixture of scheduled webinar, online anytime, and in-person training to help Schedule contractors effectively use the Schedules program to best achieve desired goals. After the webinar you should be able to:
- Describe FAR Subpart 8.4 and Part 15 procedures and how each fits into your acquisition strategy and planning Continue reading »
The FAR Council has issued the final rule entitled “Reporting Executive Compensation and First Tier Subcontract Awards.” The rule applies to contracts valued over $25,000 and requires the contractor to report the total compensation of its five most highly compensated executives if the contractor had $25 million or more in federal revenue in their last fiscal year, and 80% of their total revenue was derived from government work, and the salaries are not otherwise publicly available. The prime must obtain and submit the same salary information for any first tier subcontractors that meet the $25 million, 80%, not otherwise available criteria. In addition, the prime contractor must report a variety of other non-salary information about its first tier subcontract awards.
The final rule, issued on July 26, 2012 only slightly revised the interim rule issued over two years ago. The three changes of note were: Continue reading »
Last September, the Office of Management and Budget (OMB) issued Memorandum 11-32 “Accelerating Payments to Small Business … “ Pursuant to this memorandum, all executive agencies were instructed, to the extent practicable, to make payments to small business prime contractors within 15 days of receipt of the invoice. The administration is now taking a similar approach to accelerating payments to small business subcontractors. Continue reading »
DoD publishes FINAL Defense Business Systems Rule; Treasury Issues Internet Payment Platform Proposal
The Defense Department published in the Federal Register the final rule on Defense Business Systems, effective immediately. The rule makes fourteen changes to the current interim rule; of significance:
- DFARS 215.407-5-70(d) is removed. The criteria for maintaining an acceptable estimating system have been relocated to the clause at 252.215-7002, Cost Estimating System Requirements.
- DFARS 242.302(a)(4) has been deleted and an additional contract administration function to approve or disapprove contractor business systems has been added at DFARS 242.302(a)(S-74).
- The term “cost” has been replaced by “cost-reimbursement,” as appropriate, in DFARS 242.7000(b)(1) and DFARS 252.242-7005(e). Continue reading »
The Department of Defense (DoD) is proposing to amend the DFARS (Defense Federal Acquisition Regulation Supplement) to document the current practice of using statistical sampling to approve interim invoices. The rule clarifies that interim invoices not chosen as part of the sample to be reviewed will be considered provisionally approved for payment subject, of course to any later audit of the actual costs incurred. Continue reading »
For many, your 2011 financial audit is coming quickly (if it hasn’t already started) and, with that, your friendly Aronson auditors! While we provide you with a Prepared by Client List (PBC), here are some tips to give you greater insight into what goes on in the minds of those crazy auditors and how you can make the audit process smoother for everybody involved.
- Auditors love to get all of their information all at once. They really like walking in that first day of an audit and seeing all of the information pulled and ready in the audit room, rather than piecemeal over a period of time. Continue reading »
On February 18, 2011 the DCAA issued memorandum 11-PSP-003(R) regarding FAR 52.215-23 on Pass-Through Charge Limitations. The memo states that any indirect costs and associated profit applicable to subcontractor costs where the contractor does not provide “added value” (e.g., subcontract management functions) are considered excessive pass-through costs which are unallowable.
What We Are Writing
- A Marriage of Inconvenience: GSA Schedule Contracts & The Contractor Code of Business Ethics & Conduct Clause
- Emerging Small Businesses: To Grow Your Business, You Must Plan For Growth
- Government Contracting: Look Before You Leap!
- GSA Schedules – Strategies for Success
- New Employee vs. Independent Contractor Considerations
- Pay on Display – Understanding the Executive Compensation and Subcontractor Data Reporting Requirements & Ramifications
- The GSA Schedule: Your Ticket to the Federal Market (May 2010)
- The New FAR Codes of Conduct and Compliance Program Provisions
- The Seven Deadly Sins (of contract compliance)