Executive summaryUnited States (US) final regulations (T.D. 9921) on sourcing income from sales of personal property, including inventory (the Final Regulations), generally retain the basic approach of proposed regulations that were released in December 2019 to address changes made to Internal Revenue Code1 Section 863(b)(2) by the Tax Cuts and Jobs Act (2017) (REG-100956-19) (the Proposed Regulations).2 The Final Regulations also revise the Proposed Regulations’ guidance on sourcing income from sales of personal property under Section 865(e)(2), as well as other provisions of former Treas. Reg. Sections 1.863-3 and 1.864-5 (the Prior Regulations) that were not amended by the Proposed...