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.