Treasury Aware of Criticism Surrounding Cloud-Computing Rules

The Treasury Department is aware of criticism that examples in its proposed cloud-computing regulations “carefully avoid how a business actually operates in commerce,” a senior official said on Friday.

Wade Sutton, deputy international tax counsel at the department’s Office of International Tax Counsel, said the proposed regulations “showed a lot of careful thought and deliberation, and unfortunately this issue seems to have obscured all that good thought and work.” Sutton was answering a question about whether the department would develop a safe harbor or definition of de minimis for purposes of the guidance. He was speaking at the American Bar ...