IRS Open to New Rules on Software, Cloud Transactions, Official Says

Tax issues raised by increasingly complex digital media, software, and cloud computing transactions could be ripe for new regulations, an IRS official said April 10.

Urging input from practitioners, Anne P. Shelburne, senior counsel in the Office of the IRS Associate Chief Counsel (International), said that it may be necessary to revisit October 1998 regulations (T.D. 8785) on classifying certain computer software transactions. She spoke at the 12th Annual New York University Law School/KPMG Tax Lecture Series, “Taxation of Intangibles in a Global Economy—A Moving Target.”

The regulations address tax treatment of certain transactions involving the transfer of ...