News & Analysis as of

Rulemaking Process New Guidance Executive Orders

McDermott Will & Emery

IRS Roundup April 1 – April 17, 2025

The IRS issued Notice 2025-19, inviting the public to submit recommendations for items to include in the IRS’s 2025-2026 Priority Guidance Plan. The IRS uses the Priority Guidance Plan to identify and prioritize the tax...more

Schwabe, Williamson & Wyatt PC

NEPA’s Future Comes Into View with New Guidance and Rule Recission ‎

The past few months have been a period of high uncertainty over implementation of the National Environmental Policy Act (NEPA). In December, the Supreme Court heard arguments in a case that addressed the scope of foreseeable...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Implementation of White House Executive Orders Addressing Guidance: EPA forms Workgroups

The White House recently issued two Executive Orders (“EOs”) focusing on the use of guidance by federal agencies in the context of informing enforcement actions and restricting the use and issuance of new guidance. (See...more

King & Spalding

President Trump Issues Executive Order Limiting Agency Use of Informal Guidance Documents

King & Spalding on

On October 9, 2019, President Trump issued an Executive Order aimed to curb agencies, such as CMS, from using informal guidance documents as de facto rules that have the binding effect of law. In a press conference...more

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