To ensure a consistent and predictable business climate for Michigan taxpayers, agency guidance and rulemaking must adhere to the Administrative Procedures Act (APA). Too often, the Michigan Department of Treasury has issued “notices,” “policy directives,” “bulletins,” “frequently asked questions” and other “guidance” that is not binding on the agency and has not been vetted appropriately through the APA. We encourage the Office of Regulatory Reinvention to continue its work in developing a consistent and predictable regulatory process as part of the reinvention of Michigan tax policy.