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Section 865(e)(2)

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 taxpayerBut 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. [...]Read more

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

What’s Your Source? Proposed Regulations on Sourcing Inventory Sales

April 2, 2020 By Edward Tanenbaum and Heather Ripley

Is your inventory sales income U.S. or foreign source? Well, it depends. In case you missed it, our International Tax Group explores the various sourcing rules the IRS has proposed to sort out possible inconsistencies and overlaps caused by the Tax Cuts and Jobs Act.

Place of production now determines source for sales of produced inventory
Coordinating Section 863(b) and Section 865 for sales through an office
The overlap of Section 865(e)(2) and Section 864(c)(4)(B)(iii) for certain “nonresidents”

Read the full advisory here. [...]Read more

Filed Under: International Tax Advisory, Tax Reform Tagged With: IRS, nonresidents, Section 863(b), Section 864(c)(4)(B)(iii, Section 865, Section 865(e)(2), Tax Cuts and Jobs Act, tax reform, TCJA

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