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).

Newsletter Articles


50 years of The Tax Adviser

The January 2020 issue marks the 50th anniversary of The Tax Adviser, which was first published in January 1970. Over the coming year, we will be looking back at early issues of the magazine, highlighting interesting tidbits.


Quirks spurred by COVID-19 tax relief

This article discusses some procedural and administrative quirks that have emerged with the new tax legislative, regulatory, and procedural guidance related to COVID-19.