Layla Asali was quoted in the Wall Street Journal on the possible impact of a recent government memo outlining its likely challenge to calculations of the corporate deduction for foreign-derived intangible income (FDII) that could put the government at odds with some of the largest U.S.-based multinational companies. The Internal Revenue Service (IRS) memorandum set forth a legal argument that shows it is likely to contest the position of companies' that relied on prior IRS guidance in calculating their FDII deduction. "It seems like the IRS is trying to bolster a litigating position or warn taxpayers that they're in for a fight," Asali said.