Final Rules on Cloud Computing Transactions Released by IRS (2)

The IRS on Friday released final regulations on how the agency would characterize cloud computing transactions and transfers of digital content.

The regulations (TD 10022; RIN 1545-BM41) determine how companies classify their cloud transactions and digital content access as a provision of services or a lease of property under Section 861 of the US Tax code.

Rafic Barrage, a partner at Baker & McKenzie based in Washington, D.C., said the final regulations show that the IRS was “quite receptive” to taxpayer comments on the proposed regulations, which were released in August, 2019.

The final regulations detail a way ...