Exemption Elimination: Foreign Contractors' New Concerns

Law360, New York (August 30, 2011, 12:58 PM EDT) -- On Aug. 10, 2011, the Cost Accounting Standards Board (the “CAS Board”) issued a final rule to eliminate the Cost Accounting Standards (“CAS”) exemption (“Exemption (b)(14)”).[1] Exemption (b)(14) excused from any CAS requirements contracts and subcontracts executed and performed entirely outside the United States, its territories and possessions.

The end result is that foreign contractors will be required to comply with CAS 401 and 402, agree to CAS’ price adjustments for accounting practice inconsistencies and/or changes and submit a disclosure statement under certain circumstances. This rule...
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