In with the New: Trump Freezes Pending and Non-Issued Obama-Era Regulations
Client Alert | 1 min read | 01.23.17
On January 20, 2017, President Trump's Chief of Staff Reince Priebus issued a memorandum to the heads of the executive departments and agencies calling for a regulatory freeze pending review – a practice that is relatively routine for new incoming presidential administrations. Specifically, the memorandum prohibits agencies from sending any regulation to the Office of Federal Register (OFR) prior to review and approval; requires agencies to immediately withdraw unpublished regulations for review and approval; and mandates that agencies temporarily postpone the implementation of published, but not yet effective, regulations for 60 days. Regulations subject to statutory or judicial deadlines are excluded from the aforementioned actions, but agencies must timely identify them to the OMB Director. Agencies also may identify regulations they believe should not be subject to the aforementioned procedures, namely those affecting "critical health, safety, financial, or national security matters, or for some other reason."
Contacts
Insights
Client Alert | 3 min read | 10.15.25
On August 15, 2025, the Treasury Department and IRS released updated guidance concerning Beginning of Construction requirements to qualify for clean energy tax credits. This new guidance is critical for developers to consider as they rush to qualify for the tax credits before they expire entirely. The much-anticipated guidance followed the July 7, 2025 Executive Order 14315, Ending Market Distorting Subsidies for Unreliable, Foreign-Controlled Energy Sources (“July 7, 2025 Executive Order”), which signaled that the Trump Administration was planning to strictly enforce the termination of production and investment tax credits for solar and wind facilities that are set to expire under the One Big Beautiful Bill Act (OBBB Act), covered in more detail here. The new guidance comes at a time when many in the industry are struggling to keep up with the myriad ways that the new administration is working to roll back wind and solar tax credits, leaving developers to piece through the recent guidance to determine how best to structure and invest in clean energy projects given the volatile position of the current administration vis-a-vis wind and solar energy.
Client Alert | 10 min read | 10.15.25
Client Alert | 4 min read | 10.14.25
Client Alert | 35 min read | 10.13.25
Building Blocks of Design Law: CJEU rules on LEGO Group Modular Design Protection
