New Proposed Regulations on Cloud Computing and Digital Content Transactions
Author: Isaac J. Wheeler.; S. Eric Wang.; Jameson S. Lloyd.; Anna R. Demaree.
Source: Volume 37, Number 02, Winter 2020 , pp.13-20(8)
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Abstract:
Recently issued proposed regulations address several open issues regarding classification and tax treatment of cloud and digital content transactions. While largely confirming what has been typical industry practice and clarifying some issues, the proposed regulations highlight the importance of a user’s location in determining whether an end-user may be considered to be engaged in a U.S. trade or business for tax purposes.Keywords: REG-130700-14, Cloud Transactions, Lease of Property, Provision of Services, Digital Content, Income Sourcing
Affiliations:
1: Sullivan & Cromwell LLP; 2: Sullivan & Cromwell LLP; 3: Sullivan & Cromwell LLP; 4: Sullivan & Cromwell LLP.