On January 12, 2021, the IRS issued final regulations on
Internal Revenue Code section 162(f), as amended by the TCJA,1 concerning the deduction of certain
fines, penalties, and other amounts.2
The final regulations revise Treas. Reg. section
1.162‑21, clarify the scope of IRC section 162(f), and add
Treas. Reg. section 1.6050X, which covers new section 6050X
information related to reporting requirements. The final
regulations affect taxpayers that pay or incur amounts to, or at
the direction of, governments, governmental entities, or certain
nongovernmental entities treated as governmental entities
(collectively, "governmental entities") in relation to
the violation of a law or investigations or inquiries by these
governmental entities into the potential violation of a law
(collectively, "violation of a law").