I.  Permanent Response to Temporary Legislation

Comments: Two respondents claimed that a restriction included in an appropriations bill does not equate to a permanent restriction, whereas the Councils have responded with regulations that are permanent. The respondents believed that this "permanent" FAR language is not a proper reaction to statutes restricting use of appropriations in a given fiscal year, particularly because inevitable variations in future years' appropriations limitations on contracting with inverted domestic corporations are likely to make regulatory changes still more complicated.

Response: The Councils do not agree that this is in fact permanent coverage, because the prohibition is tied to the expenditure of specific year funds and is self-deleting over time. There is no other readily accessible means for this information to get to the contracting officers who must implement the contracting restriction.