December 2024: Reducing the Negative Impacts of a Government Shutdown for Federal Contractors
Once again, the specter of a government shutdown looms over the federal contracting community. The federal government is set to run out of funding on December 20 due to an impasse during final negotiations over added spending. The expected timeline for renegotiations is making it ever more likely that a protracted shutdown of over a month will occur. Below are key steps your business should take to mitigate the possible negative impacts of a government shutdown, along with shutdown-related labor and . . . Read More
SBA Update: Final Rule Appears Beneficial for IT Value-Added Resellers
As PilieroMazza covered here on December 17, 2024, SBA issued its much-anticipated final rule in response to the proposed rule it issued in August and the hundreds of public comments it received. One area of particular interest for IT value-added resellers (ITVARs) is how SBA finalized its proposed rule pertaining to the use of tax returns to determine a firm’s annual revenue for small business purposes. At first blush, we think the final rule—which will take effect on January 16, 2025—is . . . Read More
SBA’s Final Rule Is Here: Key Takeaways on Updates to HUBZone Program, Other Small Business Programs, and Various Small Business Matters
On December 17, 2024, the Small Business Administration (SBA) published a final rule that will make changes to its regulations for the Historically Underutilized Business Zone (HUBZone) Program, clarifying certain policies. PilieroMazza recently covered the proposed changes (linked here ), which impact not just the HUBZone Program. This final rule goes into effect on January 16, 2025, “will apply to existing contracts,” and makes several amendments impacting all GovCon small businesses. PilieroMazza ’s Government Contracts Group will release various blogs on different aspects of the final rule . . . Read More
Read Before Increasing Wages! Unraveling the Minimum Wage and Salary Basis Test Mayhem
2024 ushered in the implementation of and challenges to several wage and hour initiatives by the Biden Administration, most notably, adjustments to the salary basis test and Executive Order 14026, which raised minimum wages for government contractors. In both cases, U.S. federal courts intervened, issuing decisions that will shape how employers approach wages in 2025 and beyond. Keep reading to find out the key points contractors need to know before January 1, 2025. Overview The Biden Administration, through the . . . Read More
Seldom-Discussed CMMC Effects on a Defense Contractor’s Business
The Department of Defense (DOD) has finally promulgated its Final Rule (Rule) implementing the Cybersecurity Maturity Model Certification (CMMC) program, which goes ‘live’ on December 16th. There is plenty of content summarizing what the Rule is. Here, PilieroMazza attorneys offer their opinions on some of the practical effects, consequences, and strategies federal contractors can take away from the Rule and the DOD’s commentary. This blog touches on potential protest arguments flowing from the Rule, the Rule’s effect on small businesses and joint . . . Read More
Corporate Transparency Act, Part 5: Voluntary Reporting
In this fifth installment of PilieroMazza ’s series on the reporting requirements associated with the Corporate Transparency Act (CTA) (see links to Part 1 , Part 2 , Part 3 , and Part 4 ), we discuss the nationwide preliminary injunction halting enforcement of the CTA. While reporting companies formed prior to January 1, 2024, need not comply with the CTA’s January 1, 2025, Beneficial Ownership Information Report (BOIR) filing deadline, and reporting companies formed in 2024 similarly need not comply with the CTA’s ninety (90) day BOIR filing . . . Read More
Corporate Transparency Act, Part 4: Reporting Requirements Temporarily Suspended
As you may have been following, PilieroMazza previously reported on the requirements of the Corporate Transparency Act (CTA) and the reporting requirements that are associated therewith ( Part 1 , Part 2 , and Part 3 ). On December 3, 2024, in the case of Texas Top Cop Shop, Inc. et al. v. Garland et al., the U.S. District Court for the Eastern District of Texas issued a preliminary injunction against the enforcement of the CTA that applies nationwide. In its ruling, the court found that the “CTA is . . . Read More
Corporate Transparency Act, Part 3: Filing Extensions for Businesses Affected by 2024 Hurricanes
The Financial Crimes Enforcement Network (FinCEN) announced a significant relief measure under the Corporate Transparency Act (CTA) for businesses affected by five hurricanes impacting the U.S. in 2024. Hurricane relief extends the deadline for submitting a Beneficial Ownership Information Report (BOIR) by six months for companies that meet specific criteria. Please visit this link for Part 1 and this link for Part 2 in this series. Which Companies Qualify for the Extension? To qualify for this extension, a reporting company must meet two . . . Read More
SBA Proposes Substantive Changes to Negative Control and Unconditional Ownership and Control Considerations Across Socioeconomic Programs: Key Considerations and Takeaways
As PilieroMazza noted recently here , the Small Business Administration (SBA) released a proposed rulemaking that will impact government contractors. This client alert discusses a major proposed change that would significantly impact any small business that has a minority shareholder or investor. While the proposed rule also aims to create uniformity across SBA’s socioeconomic programs—including the 8(a) Business Development, Women-Owned Small Business (WOSB), and Service-Disabled Veteran-Owned Small Business (SDVOSB)—the proposed rule looks to undo years of case law and seriously impacts what it . . . Read More
SBA Proposed Material Changes to HUBZone Program Impacts Eligibility
As PilieroMazza noted recently here , the Small Business Administration (SBA) released a major proposed rulemaking that will impact government contractors, including those that are participants in or seeking to be admitted to the Historically Underutilized Business Zones (HUBZone) Program. PilieroMazza is posting a series of client alerts regarding SBA’s proposed rulemaking. This alert highlights some of the proposed changes pertaining specifically to the HUBZone Program that will impact small business government contractors and their contracting partners. A. Overview The HUBZone Program was established . . . Read More