Notice of Proposed Rulemaking: Classification of Cloud Transactions and Transactions Involving Digital Content

7 Pages Posted: 29 Jun 2020

See all articles by Jeffery M. Kadet

Jeffery M. Kadet

University of Washington - School of Law

Date Written: August 20, 2019

Abstract

This submission makes comments on REG-130700-14, which includes proposed regulations on the classification of cloud transactions and transactions involving digital content.

In addition to some suggested changes to reflect industry practice, the submission importantly suggests recognition and the inclusion of an example to deal with profit-shifting structures.

Keywords: cloud transactions, international taxation, sourcing of income

JEL Classification: H21, H25, K34, E62

Suggested Citation

Kadet, Jeffery M., Notice of Proposed Rulemaking: Classification of Cloud Transactions and Transactions Involving Digital Content (August 20, 2019). Available at SSRN: https://ssrn.com/abstract=3617950 or http://dx.doi.org/10.2139/ssrn.3617950

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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