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Sourcing the Source of Inventory Sales – Final Regulations Under Section 863(b)

October 26, 2020 By April McLeod and Sam Kaywood

Is inventory personal? Well, it depends. In case you missed it, our International Tax Group recently explored the finalized sourcing rules that decide whether inventory is U.S. or foreign source after changes wrought by the Tax Cuts and Jobs Act.

  • Different rules for inventory produced, rather than purchased, by the taxpayer
  • But what if foreign branches sell inventory produced in the U.S.?
  • Special rules for property sold through a U.S. office maintained by a nonresident

Read the full advisory here.

Filed Under: International Tax Advisory Tagged With: Section 1.954-3(a)(4), Section 168(g)(2), Section 861(a)(6), Section 863(b), Section 863(b)(2), Section 865, Section 865(e)(2), Tax Cuts and Jobs Act, tax reform, TCJA, title passage

About April McLeod

April counsels her clients through the labyrinth of federal and international tax laws.

About Sam Kaywood

Sam Kaywood is a partner in the Federal & International Tax Group and a co-chair of the International Team. Sam concentrates his practice on federal income tax and international tax, including cross-border M&A and joint ventures, as well as in-bound investments into the U.S.

[Read Bio]

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