IRS Regs Preview Sourcing Challenges in Taxing The Cloud


David Noren commented on new US Treasury regulations for taxing cloud computing businesses. « There could be any number of jurisdictions which might be involved in delivering cloud services to a customer, » said Noren. « It wouldn’t be unusual for a customer in France to be served in part by a local French affiliate, an Irish affiliate and a U.S. affiliate — and it’s not obvious which of the various activities really count for figuring out where the services are performed. »