The U.S. Treasury Department and the IRS posted Sec. 863(b) proposed regulations re: foreign source income from sales of inventory/personal property and determining whether foreign source income is effectively connected with a trade or business in the U.S.
The proposed regulations are expected to be published in the Federal Register on December 30, 2019, thereby becoming applicable in Q4 for calendar-year taxpayers. The document is attached for reference.
Click to access 2019-27813.pdf
Strategizing Multinational Tax Risks 
Comments on: "U.S. Sec 863(b) Prop Reg’s: Holiday Gifts" (1)
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