REG-100956-19 Public Hearing - Outline of Topics
23 Pages Posted: 16 Jun 2020
Date Written: May 19, 2020
Abstract
The Treasury and IRS issued proposed regulations [REG-100956-19] in December 2019 regarding §§863(b) and 865(e). The proposed regulations implement the TCJA's amendment to source the sale of inventory property that is produced and sold by the taxpayer at the location(s) where production occurs.
This Outline of Topics includes background and comments on:
- Need to Expand Production Sourcing to Include All Group Members
- Prop. Reg. §1.865-3 – “Purchased and Sold” or “Produced and Sold”
- Need to Re-Think Approach to Allocation in Prop. Reg. §1.863-3(c)
Keywords: Source, Sourcing of Income, effectively connected income, ECI, 863, 865, inbound, International taxation
JEL Classification: H21, H25, K34, E62
Suggested Citation: Suggested Citation