IRS Regs Preview Sourcing Challenges in Taxing The Cloud - McDermott Will & Emery

IRS Regs Preview Sourcing Challenges in Taxing The Cloud

Overview


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.”