The U.S. IRS and Treasury have issued proposed regulations on the Classification of Cloud Transactions and Transactions Involving Digital Content. The regulations are proposed to apply to taxable years beginning on or after the date of publication of the regulations as final regulations in the Federal Register. --- SUMMARY: This document contains proposed regulations regarding the classification of cloud transactions for purposes of the international provisions of the Internal Revenue Code. These proposed regulations also modify the rules for classifying transactions involving computer programs, including by applying the rules to transfers of digital content.