Inventory Sourcing Rules After the U.S. Tax Cuts and Jobs Act: Do the Changes Work?
90 Tax Notes International 1513 (June 25, 2018)
3 Pages Posted: 9 Jan 2020
Date Written: June 25, 2018
The author considers whether changes to the U.S. rules for sourcing income from inventory sales contained in the Tax Cuts and Jobs Act operate as intended in light of existing provisions that take precedence over the revised section and given the rules regarding effectively connected income. She ultimately concludes that, at least until Congress amends the law, foreign persons selling foreign manufactured inventory into the United States should consider operating through a separate U.S. company rather than a U.S. sales branch.
Keywords: Tax Cuts and Jobs Act, inventory sourcing, IRC 863(b)
Suggested Citation: Suggested Citation