The government continues to make its ad hoc remedies available for TARP recipients, in ways that are bringing into question the entire TARP program. lack of congressional oversight continues to be a major problem with the program, which has many elements of cronyism and the kind of status difference for big banks versus auto manufacturing that apparently has little to do with the public interest.
Mark Jennings, a senior official in the IRS office of associate chief counsel (corporate), spoke on December 8 at a Federal Bar Association Section of Taxation breakfast about Notice 2008-83, according to BNA's Banking Report, 91 BBR 1089. He stated that the benefit of the notice would apply to banks that had made acquisitions in prior years that remain open under the statute of limitations, thus making the benefit available for years prior to the current crisis for the benefit of any banks that made takeovers. Jennings did reiterate that the notice as issued doesn't apply to foreign banks, and that it is a "temporary" provision, though just what "temporary" means if Congress doesn't act to nullify the notice (as proposed by Bernie Sanders) is not clear. Jennings noted that more guidance on using the Notice will likely be issued, if Congress doesn't take action on the various bills dealing with the notice in the near future.
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