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joan

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Posts posted by joan


  1. contemplating a cost accounting practice change.

    Changed in CAP Scenario contemplated is over five year period would result in same expense at the end of the five years.  Net would be zero increased costs in aggregate

    However change in measurement would case more costs to be incurred in the current periods and lesser in subsequent periods.   

     GDM offsets would be appropriate because FP increased costs - - lower costs to Government, and Flexibly-priced contracts increase - - higher cost to Government

    Thoughts?

    thanks


  2. Good morning,

    Referring to ASBCA Nos.  57576, 57679, and 58290 Raytheon

    For forward pricing I propose salaries after removing a percentage for unallowable cost.  I propose 100% of bonus costs (restricted stock) as allowable.

    In proposing the 100% restricted stock cost I rely on FAR 31.201-6, Accounting for Unallowable Costs states "A directly associated cost is any cost that is generated solely …”.  “Solely” is what I am hanging my hat on. 

     

    Whereas the ACO relying upon the ASBCA decision says that I should adjust the restricted stock allowability percentage equal to the same percentage used for proposed salaries.

     

    Now I am rethinking myself after referring to FAR 31.201-6(2) Salary expenses of employees who participate in activities that generate unallowable costs shall be treated as directly associated costs to the extent of the time spent on the proscribed activity, provided the costs are material in accordance with subparagraph (e)(1) above (except when such salary expenses are, themselves, unallowable).

     

    Thoughts?

     

    Thank you


  3. Further research: as per 1984 FAR (effective April 1 1984) Lobbying is defined as any activity or communication that is intended or designed to directly influence members of the U.S. Congress or State and local legislatures, their staffs, or the staffs of committees of these bodies....... Which seems to answer part of my question. Lobbying is directed at US Government activities. Lobbying agreed is unallowable.

    However the question is would political activities as described in 2 and 5 relate to Non US Government entities?


  4. FAR 31.205-22 identifies six expressly unallowable activities associated with lobbying and political activity.

    There are four activity numbers: 1, 3, 4, and 6 which specifically identify activity related to federal, state or local governments. Whereas, activity numbers 2 and 5 do not state explicitly federal, state, or local governments.

    So do I read it in context of the other four and consider activities 2 and 5 also related to federal state and local governments?

    Or do I read as written thereby making activity 2 and 5 equally relatable to foreign governments?

    thanks for the assist

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