With fewer than 180 days until the midterm elections, Democratic Members of Congress are laying the groundwork for future congressional investigations in the event the party regains control of one or both chambers next year. Even as Democratic Members prepare for the possibility of winning the majority, developments such as the Virginia Supreme Court’s redistricting
Tax-Exempt Organizations: Treasury Announces IRS Plans to Revise Form 990
On April 23, 2026, the U.S. Department of the Treasury announced that the IRS plans to revise the Form 990 to improve transparency and provide clearer reporting on certain transactions of 501(c)(3) organizations, including government contracts, government grants, and fiscal sponsorship arrangements. In this alert, we provide a summary of the announcement, an estimate
The Pentagon’s New Sub-Unified Command for Autonomous Warfare: What It Means and Where It Might Land
On April 29, 2026, Secretary of War Pete Hegseth told the House Armed Services Committee that the Pentagon will “shortly announce a sub-unified command of autonomous warfare.” The announcement came as the Department of War (DoW) unveiled its fiscal year (FY) 2027 budget request, which proposes approximately $54 billion for the Defense Autonomous Warfare Group
The 6 Top Compliance Mistakes by Corporations in an Election Year
An election year brings ample opportunities for corporations to participate in the political process, and the current political environment can create enormous pressures to do so. But with these opportunities and pressures come legal risks and compliance burdens. Given the differing and complex rules across jurisdictions, companies should be aware of common political law issues
Don’t Forget Your California Major Donor Reports!
With redistricting, the “billionaire tax” and other ballot measures, and heated gubernatorial and other races, contributors are giving huge amounts of money this year in California state and local elections. California has a complex campaign finance system, and it can be easy to miss some of the requirements. Key among these is the requirement that
The New Executive Order on “Promoting Efficiency, Accountability, and Performance in Federal Contracting”: What Federal Contractors Need to Know
On April 30, 2026, President Trump issued an Executive Order (EO) titled, “Promoting Efficiency, Accountability, and Performance in Federal Contracting.” This EO directs agencies to make fixed-price contracts the default form of contracting, and requires agency officials to execute written justifications to use other forms of contracting. Of particular note for large contractors,
SBIR/STTR Is Back and the Department of War Is Wasting No Time
On April 20, 2026, one week after President Trump signed the Small Business Innovation and Economic Security Act (Public Law 119-83) into law, the Department of War (“DoW”) issued a press release announcing that it was “immediately advancing” a “redesigned and more focused initiative to accelerate the delivery of advanced capabilities to the warfighter.” As
Revolutionary FAR Overhaul Incorporates New “Addressing DEI Discrimination” Executive Order Provisions
As we previously covered, on March 26, 2026, President Trump issued Executive Order (EO) 14398, “Addressing DEI Discrimination by Federal Contractors,” to address “racially discriminatory DEI activities” in federal contracting. Among other things, EO 14398 directed the FAR Council to issue deviation and interim guidance within 60 days to implement the new
Indirect Doesn’t Mean Exempt: ASBCA Rejects Cross‑Motions Over U.S.-Flag Transportation Costs
The Armed Services Board of Contract Appeals’ (ASBCA) decision in Lockheed Martin Aeronautics Co., ASBCA No. 63621, reinforces a critical principle for government contractors: contract performance requirements operate independently of cost accounting classifications. Contractors cannot avoid substantive FAR and DFARS obligations—here, U.S.-flag transportation requirements—by treating costs as indirect rather than direct. In a nearly
State FARA Laws Pose Unique Constitutional Challenges
In 2025, Texas, Nebraska, Louisiana, Arkansas and Oklahoma enacted state-level foreign agent registration and disclosure regimes that were loosely modeled on the federal Foreign Agents Registration Act. And in the first few months of 2026, several states — Alabama, Florida, Iowa, Missouri and West Virginia, to name a few — have already introduced similar bills.
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