Bloomberg BNA: International Taxation of Computer Software and Cloud Computing Transactions
Bloomberg BNA recently requested that I present on the tope of International Taxation of Computer Software and Cloud Computing Transactions. The presentation will be made to tax attorneys and CPAs both within the greater Seattle area and nationally. The presentation will cover critical issues related to computer software and cloud computing transactions taking place between international borders. This includes an in depth review of the Treasury Regulations under Treas. Reg. Sec. 1.861-18. A description of the program is below:
Computer Software and Cloud Computing are ever increasingly cross border transactions. Practitioners providing guidance to technology clients must understand the potential issues and tax characterization of the transactions, in order to properly advise clients.
This program will walk through the computer software regulations under Treasury Regulation 1.861-18 (the “-18 Regs”), including the tax characterization of a computer software transaction, and tax consequences resulting from the classification. The program will also cover common planning opportunities related to cross boarder computer software transactions.
Further, the program will cover tax issues and planning considerations related to cloud computing transactions. This includes the proper tax classification of cloud computing transactions, and international tax considerations related to cloud computing including US Trade or Business/ PE considerations; sourcing cloud computing income; FDAP considerations related to cloud computing transactions; and subpart F considerations for CFCs.
The materials from the presentation can be found at the link below:
IRS CIRCULAR 230 NOTICE: ANY TAX ADVICE IN THIS COMMUNICATION IS NOT INTENDED OR WRITTEN BY HARLOWE & FALK LLP TO BE USED, AND CANNOT BE USED, BY A CLIENT OR ANY OTHER PERSON OR ENTITY FOR THE PURPOSE OF (i) AVOIDING PENALTIES THAT MAY BE IMPOSED ON ANY TAXPAYER OR (ii) PROMOTING, MARKETING OR RECOMMENDING TO ANOTHER PARTY ANY MATTERS ADDRESSED HEREIN.