In a recent FCPA Professor guest post, tax partner and tax controversy group co-founder Kat Gregor, litigation partner Ryan Rohlfsen, litigation senior attorney Yana Grishkan, and tax controversy counsel Elizabeth Smith examine how the final regulations interpreting Section 162(f) of the Code released on January 14, 2021 impact the deduction of amounts paid to the government in connection with an Foreign Corrupt Practices Act (“FCPA”) violation.  Further, this post highlights considerations in light of Section…

On March 11, 2021, President Biden signed into law the American Rescue Plan Act (ARPA), in furtherance of the fifth phase of the federal government’s response to the COVID-19 crisis. The full text of the bill is published here. The key tax provisions of the Phase 5 Stimulus are summarized in this Alert, and include the repeal of the worldwide interest allocation election, an expansion of the employee retention credit, and additional economic impact…