Today, Treasury and the IRS issued final regulations (T.D. 9721) under section 382 that adopt, without substantive change, temporary and proposed regulations published in 2014.  The final regulations affect corporations whose stock is or was acquired by Treasury pursuant to certain programs under the Emergency Economic Stabilization Act of 2008.  The final regulations provide that changes made to the section 382 segregation rules under the 2013 regulations do not apply to the sale of a program instrument by Treasury to public shareholders.  In doing so, the final regulations seek to prevent companies whose stock was acquired by Treasury from having a change in ownership when Treasury sells its holdings to public shareholders.