New IRS Regulations of Cloud Transactions and Digital Content: Sourcing Rules, Lease vs. Services Tax Treatment
A special 75-minute briefing
Recording of a 75-minute premium CLE/CPE webinar with Q&A
This CLE/CPE course will provide tax counsel and advisers a detailed analysis of the taxation of cloud transactions and digital content. The panel will discuss applicable IRS tax rules and recent regulations, sourcing of income rules and challenges, treatment of payment of services versus lease payments, treatment of fees for the right to use digital content, issues presented by the BEAT, GILTI and FDII rules, and other vital items impacting taxpayers engaging in cloud transactions and digital content.
Outline
- Recent IRS regulations and applicable tax rules
- Sourcing of income rules and challenges
- IRS treatment of payment of services, lease payments, and rights to use digital content
- Tax implications of BEAT, GILTI, and FDII rules in relation to cloud transactions and digital content
- Best practices for tax counsel and advisers to ensure tax compliance for cloud transactions and digital content
Benefits
The panel will review these and other key issues:
- Recent IRS regulations covering the tax treatment of cloud transactions and transfers of digital content
- Lease vs. services treatment in cloud transactions
- Digital content transfers and the tax treatment of payments for the purchase of or the right to use software or other digital content
- Sourcing rules and pitfalls to avoid unnecessary tax liability
- Additional federal income tax implications; BEAT, treatment of CFCs, FDII
Faculty
David N. de Ruig
Senior Manager - National Tax - International Tax Services
Ernst & Young
Mr. de Ruig recently joined EY’s National Tax ITS practice in the Silicon Valley, where he focuses on a... | Read More
Mr. de Ruig recently joined EY’s National Tax ITS practice in the Silicon Valley, where he focuses on a broad variety of international tax matters, with a particular emphasis on tax planning for the impact of global tax law related to intellectual property. He also brings extensive experience addressing cross-border payments and international corporate structures. Prior to joining EY, Mr. de Ruig was a tax associate at a leading global law firm where he advised on U.S. tax considerations in connection with restructuring international operations for multinational clients.
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Zachary Perryman
Managing Director
Ernst & Young
Mr. Perryman is a senior manager in EY’s National Tax Department, based in San Francisco. He advises clients in... | Read More
Mr. Perryman is a senior manager in EY’s National Tax Department, based in San Francisco. He advises clients in many sectors on a range of corporate transactional matters including intellectual property alignment, transfer pricing, international restructurings, and mergers and acquisitions.
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Barbara Tolbert
Manager - National Tax - International Tax & Transaction Services
Ernst & Young
Ms. Tolbert is a Manager in EY’s National Tax ITS practice, based in San Francisco. She advises clients on... | Read More
Ms. Tolbert is a Manager in EY’s National Tax ITS practice, based in San Francisco. She advises clients on international tax matters, including inbound and outbound planning, intellectual property alignment, global operating model restructuring, and intercompany transactions and arrangements. Ms. Tolbert’s work is primarily focused on the modern tax planning issues resulting from the rapidly changing global tax law landscape, particularly as it relates to intellectual property, digital disruption, and industry convergence.
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