Davis Polk partner Michael Mollerus was quoted in the Wall Street Journal on the IRS’ reversal of its stance on the corporate tax deduction for foreign-derived intangible income (FDII). The reversal could require companies that had calculated the deduction previously to pay additional tax bills. Michael noted that this is a “significant step and not one that they would take lightly.”

IRS, Reversing Course, Tees Up Potential Tax Fight With Multinational Companies,” Wall Street Journal (May 17, 2022) (subscription required)