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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.

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

About Edward Tanenbaum

Edward Tanenbaum is co-chair of the firm’s Federal & International Tax Group and a member of the firm’s Global Resources & Strategies Committee. Mr. Tanenbaum’s practice consists primarily of planning and structuring tax efficient solutions for cross-border business transactions and investments by foreign multinational corporations and high-net-worth individuals.

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About Heather Ripley

Heather Ripley is an associate in the firm’s Federal & International Tax Group. Her practice focuses on federal and international tax services for a range of clients, including domestic and international business entities and individuals.

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