Document summaries for the week of Dec. 23, 2019
Rules proposed on source of income from sales of personal property
The IRS issued proposed regulations that modify the rules for determining the source of income from sales of inventory produced within the United States and sold outside the United States, or vice versa. They also contain new rules for determining the source of income from sales of personal property (including inventory) by a nonresident where those sales are attributable to an office or other fixed place of business that the nonresident maintains in the United States. The proposed regulations also modify certain rules for determining whether foreign-source income is effectively connected with the conduct of a trade or business within the United States. REG-100956-19 (12/23/19).
Regulations on withholding and reporting on US-source income paid to foreigners
The IRS issued final regulations on due diligence and reporting rules for persons making U.S.-source payments to foreign persons and on reporting by foreign financial institutions on U.S. accounts. T.D. 9890 (12/27/19).