Corporate Transparency Act, Part 10: Interim Final Rule, U.S. Companies and U.S. Persons Exempt From Reporting
On March 26, 2025, FinCEN issued an interim final rule and request for comments, removing the requirement under the Corporate Transparency Act (CTA) for both U.S. companies and U.S. persons to report beneficial ownership information to FinCEN. The rule is effective March 26, 2025. Thus, subject to additional rule changes, U.S. companies and U.S. individuals no longer have to file an initial Beneficial Ownership Information Report (BOIR) or otherwise update or correct a previously filed BOIR. Please visit this link to access Parts 1-9 . . . Read More
President Trump’s DEI Executive Orders Are Back On: What Contractors Need To Know
On March 14, the Fourth Circuit stayed a preliminary injunction that had prohibited President Trump’s administration and federal agencies from implementing Executive Orders 14151 and 14173 (“DEI Executive Orders”). This means the Trump administration can proceed with implementing the DEI Executive Orders pending ongoing litigation. In this blog, we discuss what federal contractors should take away from the Fourth Circuit’s order. Executive Orders 14173 and 14151 are the primary mechanisms President Trump has used to wind down certain Diversity, Equity, . . . Read More
GSA to Oversee Federal Purchasing: A Step Toward Efficiency or a Challenge for Agencies and Contractors?
On March 20, 2025, President Trump signed an executive order to consolidate federal procurement under the General Services Administration (GSA). Framed as an effort to eliminate waste and save taxpayer dollars, the order mandates that federal agencies shift their purchasing of common goods and services to the GSA. While this move is being touted as a step toward efficiency, the reality may be far more complex for government contractors. What Does the Executive Order Require? The order mandates several major changes to . . . Read More
No More Minimum Wage Obligations Shifts Pricing Strategies for Service and Construction Contractors
On Friday, March 14, 2025, President Trump revoked Executive Order 14026, Increasing the Minimum Wage for Federal Contractors (EO). Government contractors in the service and construction sectors should evaluate how Trump’s decision to cancel the EO will impact their pricing strategies and outstanding price adjustment requests. Effective immediately, contractors are no longer bound by EO 14026’s minimum wage requirements. This means that most service and construction contractors may revert employee pay to the applicable wage determination rates under their contracts. . . . Read More
March 2025: Reducing the Negative Impacts of a Government Shutdown for Federal Contractors
On top of the uncertainty introduced through the Trump administration’s shifting priorities and rapid-fire executive orders, government contractors are now confronted with an impending shutdown as the federal government is set to run out of funding on March 14. Although the House of Representatives passed a six-month continuing resolution that would keep funding at current levels through the rest of the fiscal year (i.e., September 30), it remains to be seen whether the Senate has the votes to pass the . . . Read More
Court Blocks Suspension and Termination of Foreign Aid Contracts: Key Takeaways for Government Contractors
In a landmark decision, Judge Ali has issued a preliminary injunction (PI) preventing the U.S. government from enforcing suspensions, stop-work orders, and terminations for foreign aid contracts issued between January 20 and February 13, 2025—the date on which Judge Ali issued a temporary restraining order in this case. The ruling is a major rebuke of the executive branch’s attempt to halt congressionally appropriated funds, reaffirming Congress’s constitutional spending authority. This ruling requires the government to resume payments and allow drawdowns for . . . Read More
Corporate Transparency Act, Part 9: Reporting Due March 21, 2025, No Penalties for Not Reporting (For Now)
On February 18, 2025, the final court order [1] blocking reporting under the Corporate Transparency Act (CTA) was lifted. Thus, the CTA’s reporting requirements are back in effect, and the new reporting deadline for most reporting companies is March 21, 2025; however, FinCEN has announced that no penalties or fines will currently be enforced for not reporting. Please visit this link to access Parts 1-8 in this series. Although reporting requirements are back in effect, penalties and fines will not be enforced for . . . Read More
2nd Court Blocks Government Funding Freeze: 5 Takeaways for Contractors
A second federal judge indefinitely blocked the Trump administration’s blanket freeze on appropriated and obligated federal funds for government contractors, reinforcing Congress’s authority over government spending. This decision directly impacts government contractors who rely on federal funding for projects and operations. Key Takeaways for Government Contractors Funding Pause Declared Unlawful The court ruled that the executive branch cannot impose a blanket freeze on congressionally appropriated funds. Judge McConnell wrote, “[t]he Executive put itself above Congress. It imposed a categorical mandate on . . . Read More
SCOTUS Greenlights Release of Foreign Aid Funds to Government Contractors
On March 5, 2025, the United States Supreme Court (SCOTUS) upheld a federal judge’s order directing the government to pay nearly $2 Billion to federal contractors for completed foreign aid work. [1] This client alert identifies key takeaways from the SCOTUS denial and provides important considerations for government contractors whose payments were subject to executive freezes on foreign aid spending. Background As previously reported by PilieroMazza , President Trump issued Executive Order 14169, “ Reevaluating and Realigning United States Foreign Aid ,” which ordered agencies with foreign development assistance programs . . . Read More
Tariffs on Products from Canada, Mexico, and China: Rising Costs and Supply Shortages for Government Contractors
PilieroMazza recently published a client alert regarding executive orders issued on February 1, 2025, imposing additional tariffs on products from Canada, Mexico, and China, and the decision to delay the tariffs on Canada and Mexico until March 6, 2025. This client alert provides government contractors with an update on these tariffs—which may increase the cost of performance or lead to supply shortages, resulting in delays—and how to insulate your business. To summarize, products from Canada and Mexico were subject to a 25% tariff, . . . Read More