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U.S. Proposed Regulation Published on Source of Income from Cross-Border Inventory Sales

30 December 2019

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Approved Changes

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United States

The U.S. IRS and Treasury have issued proposed regulations on Source of Income from Certain Sales of Personal Property, which were published in the Federal Register on 30 December 2019. The proposed 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...