News & Analysis as of

U.S. Treasury Public Comment

Latham & Watkins LLP

Banking Regulators Propose to Ease Enhanced Supplementary Leverage Ratio for Large US Banks

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The proposal aims to free up large bank balance sheets and promote US Treasury market intermediation, which the current regulations may hinder....more

Ward and Smith, P.A.

Corporate Transparency Act Shakeup: Domestic Companies off the Hook, Foreign Entities Still Reporting

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This interim final rule, released on March 21, 2025, means that only foreign entities registered to do business in the United States will still need to meet the CTA’s reporting requirements. Originally enacted to increase...more

Bowditch & Dewey

Corporate Transparency Act – CTA for Foreign Reporting Companies Only

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On Friday, March 21, 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule that eliminates reporting requirements for domestic reporting companies via redefining “reporting company” to include...more

Fox Rothschild LLP

Corporate Transparency Act Narrowed

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The U.S. Treasury Department has significantly scaled back the reach of the Corporate Transparency Act (CTA). Under a new interim final rule released by Financial Crimes Enforcement Network (FinCEN), U.S.-formed companies...more

Flaster Greenberg PC

Corporate Transparency Act Update - FinCEN Interim Rule

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On March 21, FinCEN issued an interim rule that implements the reduced scope of the Corporate Transparency Act (“CTA”) previously announced on March 2....more

Kelley Drye & Warren LLP

Treasury Issues Final Rule on Outbound Investments to China

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On October 28, 2024, the Treasury Department issued its final regulations (the Final Rule) implementing new controls on outbound investments under Executive Order 14105, issued on August 9, 2024 by President Biden. This Final...more

Holland & Knight LLP

Treasury Department, IRS Release Section 30C Proposed Regulations

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The U.S. Department of the Treasury and IRS on Sept. 19, 2024, released proposed regulations under Section 30C of the Internal Revenue Code providing important clarity on the changes made by the Inflation Reduction Act (IRA)....more

Holland & Knight LLP

Tribal GWE Proposed Regulations Are an Overdue Win for Indian Country

Holland & Knight LLP on

The U.S. Department of the Treasury and IRS on Sept. 17, 2024, issued Proposed Regulations on the Tribal General Welfare Exclusion Act of 2014 (the Act). The Proposed Regulations are an overdue win for Indian country,...more

White & Case LLP

Proposed Regulations Issued for Outbound Investment Program: Key Takeaways

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On June 21, 2024, the US Department of the Treasury issued a Notice of Proposed Rulemaking (“Proposed Rule”) to implement Executive Order 14105 (“EO”) establishing a new Outbound Investment Program ("OIP") to prohibit or...more

Cadwalader, Wickersham & Taft LLP

U.S. Treasury Proposes Regulation of U.S. Outbound Investments

On June 21, 2024, the U.S. Department of Treasury (“Treasury”) issued a notice of proposed rulemaking (“Proposed Rule”) that would regulate certain U.S. transactions with persons of a country of concern involved in the...more

Blank Rome LLP

Outbound and Down: Key Takeaways from Treasury’s NPRM

Blank Rome LLP on

The U.S. Department of the Treasury (“Treasury”) recently issued a Notice of Proposed Rulemaking (“NPRM”), setting the stage for regulation of certain U.S. outbound investment in China and China-linked companies. This NPRM is...more

Latham & Watkins LLP

US Treasury Department Issues Notice of Proposed Rulemaking on Implementation of Outbound Investment: 5 Key Takeaways

Latham & Watkins LLP on

The proposed regulations would implement President Biden’s Executive Order that restricts certain outbound investments from the US. On June 21, 2024, the US Department of the Treasury (Treasury) issued a Notice of Proposed...more

Eversheds Sutherland (US) LLP

Treasury proposes expansion of CFIUS authorities

On April 11, 2024, the US Department of the Treasury issued, for notice and comment, proposed modifications (Proposed Rule) to certain Committee on Foreign Investment in the United States (CFIUS or Committee) regulations. In...more

Pillsbury - Global Trade & Sanctions Law

Treasury Announces Proposed Rule to Update CFIUS Regulations and Bolster Enforcement

On April 11, 2024, the U.S. Department of the Treasury (Treasury), as Chair of the Committee on Foreign Investment in the United States (CFIUS), issued a Notice of Proposed Rulemaking (NPRM), which is the first substantive...more

Wilson Sonsini Goodrich & Rosati

CFTC Proposes Guidance Regarding the Listing of Voluntary Carbon Credit Derivatives, and Requests Comment from the Public

On December 4, 2023, the Commodity Futures Trading Commission (CFTC) issued proposed guidance relevant to “designated contract markets” (DCMs) and “swap execution facilities” (SEFs) as they develop standardized derivative...more

Nelson Mullins Riley & Scarborough LLP

The Drive for Equitable Healthcare Access: Departments Seek Public Input on Over-the-Counter Preventive Services

On September 29, the Centers for Medicare & Medicaid Services (CMS) reported that the federal Departments of Health and Human Services, Labor, and the Treasury departments are seeking public input on the possibility of...more

A&O Shearman

Treasury Proposes New Regulatory Regime For Certain Outbound Investments

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After over a year of anticipation, on August 9, 2023, President Biden issued an Executive Order (“EO”) outlining a new regulatory regime for outbound investments from the United States. The EO targets certain U.S. investments...more

Dorsey & Whitney LLP

Executive Order 14105 on Outbound Investment in China and Proposed Rule

Dorsey & Whitney LLP on

On August 9, President Biden issued Executive Order 14105 (“EO 14105”) on Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern. EO 14105 significantly reshapes...more

A&O Shearman

Biden Administration Moves to Restrict Outbound Investment to China

A&O Shearman on

On August 9, 2023, the Biden Administration issued a long-awaited Executive Order (the EO) that is intended to address the potential national security threats posed by outbound investment from the United States to certain...more

Torres Trade Law, PLLC

President Biden Issues Executive Order Addressing Outbound Investments

Torres Trade Law, PLLC on

On August 9, 2023, President Biden issued an Executive Order (“E.O.”) on outbound investment regulation. This long-anticipated action marks the first time the U.S. government has sought to regulate investments made abroad by...more

Dorsey & Whitney LLP

Outbound Investment Screening Becomes a Reality

Dorsey & Whitney LLP on

On August 9, after months of deliberations, President Biden issued a new Executive Order on Addressing United States Investments in Certain National Security Technologies and Products in Countries of Concern (the “EO”)....more

Morgan Lewis - ML Benefits

New IRS Q&A Regarding EPCRS Expansion Answers Some – But Not All – Questions

The Internal Revenue Service (IRS) released Notice 2023-43 (Notice) on May 25, which provided guidance regarding the expansion of the IRS’s Employee Plans Compliance Resolution System (EPCRS) mandated by Section 305 of the...more

Morgan Lewis - Tech & Sourcing

Flood Insurance for Cyberattacks? A Federal Proposal

The US Treasury Department has issued a request for public comment on a federal cyberinsurance program that would aim to cover the costs associated with severe cyberattacks. The Federal Insurance Office (FIO) and the US...more

Mintz - Energy & Sustainability Viewpoints

Public Comments Requested on Additional Aspects of the IRA Clean Energy Tax Incentives, including Clean Hydrogen Production,...

On November 3, 2022, the U.S. Department of Treasury (Treasury) and Internal Revenue Service (IRS) released three Notices requesting public comments by December 3, 2022, on certain additional aspects of the clean energy tax...more

Brownstein Hyatt Farber Schreck

IRS Solicits Public Comments on Additional Inflation Reduction Act Energy Tax Credits

Earlier today, Nov. 3, the IRS issued three new public notices concerning upcoming energy guidance on five of the tax incentives included in the recently passed Inflation Reduction Act (IRA). Each notice includes a brief...more

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