Last week, on October 2, 2017, the U.S. Department of the Treasury (the “Treasury”) delivered a report to President Trump that proposes substantial revisions to eight sets of controversial U.S. federal income tax regulations (the “Report”).

The Report was prepared in response to Executive Order 13789, which was issued by President Trump earlier this year in April (the “Order”). The Order directed the Secretary of the Treasury to identify tax regulations issued on or after January 1, 2016 that impose an undue burden on U.S. taxpayers, add unnecessary complexity to the federal tax laws, or exceed the statutory authority of the Internal Revenue Service. Following the issuance of the Order, Treasury later prepared a notice in June of this year (Notice 2017-38) that initially identified the eight sets of regulations that are the subject of the Report and that were effectively targeted for potential withdrawal or revision.