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Partnership Compliance Insights

Taxation of Cloud Based Transactions – What do you see?

On August 14, 2019, the IRS released Proposed Treasury Regulation (“Prop. Treas. Reg.”) § 1.861-19 to provide rules for classifying a cloud based transaction (“CBT”) as either a lease of property or sale of services. This classification is critical to determine whether income and deductions are U.S.- or foreign-source, and it also has consequences for the calculation of the BEAT tax under Code section 59A (services are generally excluded from […]

August 19, 2019

Washington Tax Insight August 2019

Politics and Congressional Activity The Senate and the House approved legislation called the Bipartisan Budget Act of 2019 that would suspend the statutory debt limit until mid-2021 and lift the statutory caps on discretionary spending for the next two years (the “sequester”).  The President has said that he will sign the bill.  The budget deal does not include any tax measures, such as tax extenders, technical corrections, or retirement security […]

August 1, 2019

Washington Tax Insight July 2019

Politics and Congressional Activity H0use and Senate leadership continue to meet with White House officials in an effort to work out a two-year budget deal that would also address the issue of the debt ceiling limit.  If they can successfully agree on a two-year deal rather than just a one-year measure, the path to writing spending bills and avoiding another government shutdown becomes clearer. Congress passed a $19 billion disaster […]

July 16, 2019