In two recent Bloomberg Law articles, Kat Gregor comments on rules governing deductibility of payments enacted to governments as part of 2017 tax reform, including deporting requirements under section 6050X of the Code. The purpose of these new guidelines is to “boost transparency in corporate settlements and make it easier for the IRS to keep track of how much of a settlement payment a company is required to pay off.” Kat specifically notes that the Code’s vague standard might lead to misinterpretation by foreign courts as to what constitutes as restitution or compliance payments (as compared to non-deductible payments).

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