Analysis

IRS Regs Preview Sourcing Challenges In Taxing The Cloud

Law360 (August 15, 2019, 8:36 PM EDT) -- Cloud computing has baffled tax practitioners with its amorphous nature and murky business model, and while long-awaited U.S. Treasury regulations answered some questions, knottier issues such as sourcing income to a specific jurisdiction and unbundling hybrid transactions remain unresolved.

A gamer plays Electronic Arts' Apex Legends in Jersey City, New Jersey. (AP) The rules, released Aug. 9, confirmed what has become standard practice in the industry: that cloud computing, defined as on-demand network access to computer hardware or digital content, should be treated in most instances as a service, not a lease of property. The seemingly semantic difference can have significant implications for...

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