The IRS and Treasury issued proposed regulations under section 597 of the Internal Revenue Code.  The proposed regulations would modify and clarify treatment of transactions in which banks and domestic building and loan associations receive federal financial assistance (FFA).  The proposed regulations remove references to “highest guaranteed value” and instead provide guidance on the determination of fair market value of covered assets.  The proposed regulations also provide guidance for certain transactions involving non-consolidated affiliates of an institution, and make changes to facilitate e-filing.  Comments on the proposed regulations are requested by August 18, 2015.