George Hani commented on the potential impact of the regulatory freeze on the U.S. Department of the Treasury and Internal Revenue Service. The January 20 memorandum appears to include a freeze on all notices, revenue procedures and regulations, which would make this freeze "unique" and more broad than similar actions by past presidents, Hani said. He expects the freeze will be in place "as a practical matter" until the top appointed Treasury positions are filled, as those officials generally have to sign off on new regulations.  Once those roles are filled, "then it's a question of how long it will take them to get up to speed and how the different pieces of guidance are prioritized by them," Hani said.

This article was also published by Bloomberg BNA on February 24, 2017.