On August 24, 2019, the Treasury Department and the IRS issued proposed regulations regarding the classification of cloud transactions for purposes of the international provisions of the Code. The proposed regulations also modify the rules for classifying transactions involving computer programs, including by applying the rules to transfers of digital content.
We have created charts of certain examples included in the proposed regulations. View these charts and over a thousand other free charts at andrewmitchel.com (listed in topical order or listed in alpha-numeric order).
Prop. Reg. 1.861-18(h)
Example 19 (E-Book Downloads Are Sales (e.g., Amazon))
Example 20 (Non-Perpetual Right to Downloaded Songs Are Leases)
Example 21 (Movie Streaming is a Cloud Transaction, Movie Downloading is a Lease or a Sale)
Prop. Reg. 1.861-19(d)
Example 1 (Supplying Computing Capacity: Provision of Services)
Example 2 (Supplying Computing Capacity on Dedicated Servers: Provision of Services)
Example 5 (Downloaded Software Not a Cloud Transaction)
Example 6 (Online Word Processing, Etc. Via Browser or App: Provision of Services)
Example 7 (Downloaded Word Processing, Etc.: Lease of Copyrighted Article (e.g., Office 365))