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U.S. IRS Issues Final Regulations on Source of Income from Cross-Border Inventory Sales

01 October 2020

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Approved Changes

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United States

The U.S. IRS and Treasury have issued final regulations on Source of Income from Certain Sales of Personal Property (TD 9921), which are pending publication in the Federal Register. The regulations concern changes made by the Tax Cuts and Jobs Act (TCJA) regarding sources of income and include: Modified rules for determining the source of income from sales of inventory produced within the U.S. and sold without the U.S. or vice versa; New rules for determining the source of income from sales of personal property (including inventory) by non-residents that are attributable to an office or other fixed place of...