On 11 October 2016, Senate Finance Committee Chairman Orrin Hatch R-UT sent a letter to Treasury Secretary Jacob Lew seeking clarification on the use of a long-secret Memorandum of Agreement (MOA) with the Office of Management and Budget (OMB) concerning the economic and regulatory effects of tax regulations. Treasury uses the MOA to justify forgoing a cost-benefit analysis required by federal law and executive order when issuing tax regulations, including the proposed debt-equity regulations under Internal Revenue Code section 385. In the letter, Hatch asks for a response by no later than 2 December 2016, and before any final regulations...