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
Pending developments this year are focused on the Tax Cuts and Jobs Act (TCJA).
This week expectations – Final FTC Regs, final and proposed BEAT Regs
This year (maybe) – Final and proposed Sec. 163(j) Regs (currently at 550 pages)
This year/January 2020 – Sec 267A final and proposed Regs, Sec 863(b) sourcing proposed Regs
by June 30, 2020 – Final FDII regulations, GILTI high-tax exclusion, Sec 250 participation exemption
EY’s Global Tax Alert provides further details, including OECD developments reported on previously
Click to access 2019G_005186-19Gbl_Report%20on%20recent%20US%20intl%20tax%20developments%20-%2015%20Nov%202019.pdf