Tag Archives: CRA

OMB’s “Major” Move on Regs & Guidance

by Bridget C.E. Dooling — Monday, Apr. 15, 2019@BridgetDooling

The Office of Management and Budget issued a memo on Thursday describing its new approach to its implementation of the Congressional Review Act (CRA). Under the CRA, the Office of Information and Regulatory Affairs (OIRA) is required to determine whether agency “rules” are “major.” In this memo, OMB calls for information about economic impacts to inform its […]

The CRA Spring Gun May Soon Fire its First Shot

by Bridget C.E. Dooling — Wednesday, Nov. 21, 2018@BridgetDooling

Earlier this month the U.S. Department of Labor (DOL) issued a proposed rule that may turn out to be the first opportunity to test the Congressional Review Act (CRA) post-disapproval restriction on rulemaking. The CRA authorizes Congress to use an expedited process to nullify recent rules. It has been used successfully 17 times, 16 of which […]

Don’t Write Off the Congressional Review Act Yet, by Susan E. Dudley

by Guest Blogger — Monday, Nov. 6, 2017

Last Wednesday, President Trump signed his fifteenth congressional resolution disapproving a federal regulation. This was notable not only because, prior to this year, only one such resolution had ever been enacted, but also because it was the first time a president had disapproved a regulation issued during his own tenure. This, along with new opinions […]

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Reactions to the GAO Report Highlighting Flawed IRS Rulemaking Procedures

by Andy Grewal — Thursday, Sept. 15, 2016

At the request of Senator Hatch and other lawmakers, the Government Accountability Office recently released a report on various IRS guidance procedures.  The report’s title (“Treasury and OMB Need to Reevaluate Long-standing Exemptions of Tax Regulations and Guidance”) gives away its conclusion — the Treasury and OMB have not carefully considered why the government creates […]

More Thoughts on the IRS’s Failure to Comply with the Congressional Review Act

by Andy Grewal — Thursday, Aug. 11, 2016

  In a prior post, I discussed concerns expressed by Senator Hatch regarding the IRS’s failure to subject its “major” regulations to the procedures required by the Congressional Review Act (CRA). Major regulations are generally those that have economic effects of $100 million or more and would seem to include many tax regulations.  However, as […]