Two weeks ago, on September 2, 2020, the Centers for Disease Control (“CDC”) relied on little-known statutory powers to issue a temporary moratorium for most residential evictions, with a stated goal of reducing the risk of...more
9/17/2020
/ Administrative Procedure Act ,
Anti-Commandeering ,
Centers for Disease Control and Prevention (CDC) ,
Contracts Clause ,
Coronavirus/COVID-19 ,
Eviction ,
Financial Distress ,
Landlords ,
Moratorium ,
Rental Property ,
Right of Access ,
Rulemaking Process ,
Supremacy Clause ,
Tenants
Two months ago, without any prior warning or public notice, the IRS issued Notice 2016-66 which defined a number of common captive insurance transactions as “transactions of interest.” The Notice is limited to captive...more