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

See all articles by Monica Gianni

Monica Gianni

California State University Northridge

Date Written: June 25, 2018

Abstract

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

Gianni, Monica, Inventory Sourcing Rules After the U.S. Tax Cuts and Jobs Act: Do the Changes Work? (June 25, 2018). 90 Tax Notes International 1513 (June 25, 2018), Available at SSRN: https://ssrn.com/abstract=3504281

Monica Gianni (Contact Author)

California State University Northridge ( email )

David Nazarian College of Business and Economics
18111 Nordhoff
Northridge, CA 91330-8372
United States
8186772449 (Phone)

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