Foreign Cloud Computing Transactions: U.S. Taxation of Service, Intangible, Copyright, and Royalty Income
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This webinar will discuss U.S. taxation of foreign computer programs and cloud computing transactions. Our panel of international tax attorneys will explain U.S. sourcing rules for overseas digital commerce and the latest regulations relating to taxation and classification of computer-related business activity.
Outline
- Foreign computer and cloud transactions: an introduction
- Taxation of U.S. source income
- Character of income
- Service
- Intangible
- Copyright
- Royalty
- Proposed Section 861 regulations
- Best practices
Benefits
The panel will cover these and other critical issues:
- Distinguishing whether a cloud transaction is a lease of property or provision of services
- Determining whether specific digital transactions are U.S. or foreign sourced income
- How proposed regulations under Section 861 affect taxation of digital transactions
- What is considered copyright income and how it is taxed
Faculty
Anthony V. Diosdi
Partner
Diosdi & Liu
Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax... | Read More
Mr. Diosdi is an experienced trial lawyer who regularly defends individuals and corporations in matters involving tax controversies and government regulatory enforcement. He also has vast experience assisting clients who find themselves with unreported or undeclared bank accounts outside the U.S. Mr. Diosdi is acknowledged as one of the nation’s leading experts in contesting penalties associated with failing to file FBARs. In addition to representing clients in tax controversy matters, he advises clients on U.S. international tax matters, including tax planning with respect to their structures and transactions. In particular, Mr. Diosdi has experience advising on issues relating to tax treaties, pre-immigration planning for foreigners moving to the U.S., expatriation planning, tax planning for foreign companies doing business in the U.S., and subpart F income minimization. More recently, he has focused on helping clients navigate U.S. tax reform, including the regimes for Global Intangible Low-Taxed Income and Foreign-Derived Intangible Income, and the new limitations on foreign tax credits.
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Kerrin N.T. Liu
Partner
Diosdi & Liu
Ms. Liu focuses on civil tax litigation, representation before Internal Revenue Service Criminal Investigations,... | Read More
Ms. Liu focuses on civil tax litigation, representation before Internal Revenue Service Criminal Investigations, domestic tax compliance, and international tax compliance. She has represented clients as second chair in trials before the United States Tax Court. Kerrin also handled Internal Revenue Service, State of California, and FBI criminal investigation cases involving individuals and business entities. In addition, Ms. Liu has assisted clients in a broad range of tax resolution cases.
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