REG-100956-19 Public Hearing - Outline of Topics

23 Pages Posted: 16 Jun 2020

See all articles by Jeffery M. Kadet

Jeffery M. Kadet

University of Washington - School of Law

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

Kadet, Jeffery M., REG-100956-19 Public Hearing - Outline of Topics (May 19, 2020). Available at SSRN: https://ssrn.com/abstract=3607608 or http://dx.doi.org/10.2139/ssrn.3607608

Jeffery M. Kadet (Contact Author)

University of Washington - School of Law ( email )

William H. Gates Hall
Box 353020
Seattle, WA 98105-3020
United States

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