The U.S. Department of the Treasury and IRS have introduced final regulations that redefine cloud transactions as services for sourcing purposes, aiming to bring clarity and consistency to the international taxation of cloud services. Of counsel Paul Oosterhuis, associate Will Shirey and law clerk Moshe Gershenfeld analyze the implications of these regulations, discussing the potential for achieving multinational consensus, the challenges of factor apportionment and the importance of aligning with existing international norms to avoid double taxation and mismatches in taxing cross-border cloud services income.
Cloud Services Sourcing Regulations: Moving in the Right Direction?
Tax Notes Federal