The 2025 Final Regulations adopt a new "predominant character" test for characterizing digital content and cloud transactions with multiple elements, introduce a new sourcing rule for sales of electronically transferred copyrighted articles that is based on the customer's billing address and provide several examples of common digital content and cloud business models. The 2025 Proposed Regulations would provide long-awaited guidance that bases the sourcing of cloud transactions on specified intangible property, personnel and tangible property costs.Notice 2025-6 requests comments on potentially expanding the application of these rules. On January 14, 2025, the United States (US) Department of Treasury (Treasury) and the...