This spring, the IRS announced that certain disgorgement payments made to the SEC for FCPA violations were not deductible expenses under Internal Revenue Code Section 162(f). The IRS did, however, leave open the possibility that in some other factual scenarios, FCPA disgorgement penalties could serve purposes that would allow them to qualify for deductibility. Shearman and Sterling partner Lawrence M. Hill, who specializes in tax controversies, discusses the implications of the IRS position paper in a guest article. See “Are Legal Settlements Tax Deductible? (Part One of Two)” (Nov. 19, 2014); “Ten Strategies to Maximize the Tax Deductibility of Settlements (Part Two of Two)” (Dec. 3, 2014).